Jan. 2, 2007

RiverSource Life Insurance Company
(previously American Enterprise Life Insurance Company)
829 Ameriprise Financial Center
Minneapolis, MN 55474

RE:     RiverSource MVA Account
        (previously American Enterprise MVA Account)
        RiverSource Life Insurance Company
        (previously American Enterprise Life Insurance Company)
              RiverSource AccessChoice Select(SM) Variable Annuity
              RiverSource Endeavor Select(SM) Variable Annuity
              RiverSource FlexChoice(SM) Variable Annuity
              RiverSource FlexChoice(SM) Select Variable Annuity
              RiverSource(SM) Galaxy Premier Variable Annuity
              RiverSource Innovations(SM) Variable Annuity
              RiverSource Innovations(SM) Select Variable Annuity
              RiverSource Innovations(SM) Classic Variable Annuity
              RiverSource Innovations(SM) Classic Select Variable Annuity
              RiverSource New Solutions(SM) Variable Annuity
              RiverSource Pinnacle(SM) Variable Annuity
              RiverSource Signature(SM) Variable Annuity
              RiverSource Signature(SM) Select Variable Annuity
              RiverSource Signature(SM) One Variable Annuity
              RiverSource Signature(SM) One Select Variable Annuity
              Evergreen Essential(SM) Variable Annuity
              Evergreen New Solutions Variable Annuity
              Evergreen New Solutions Select Variable Annuity
              Evergreen Pathways(SM) Variable Annuity
              Evergreen Pathways(SM) Select Variable Annuity
              Evergreen Privilege(SM) Variable Annuity
              Wells Fargo Advantage(R) Variable Annuity
              Wells Fargo Advantage(R) Select Variable Annuity
              Wells Fargo Advantage(R) Builder Variable Annuity
              Wells Fargo Advantage(R) Builder Select Variable Annuity
              Wells Fargo Advantage Choice(SM) Variable Annuity
              Wells Fargo Advantage Choice(SM) Select Variable Annuity
        Form S-1 Initial Registration Statement

Ladies and Gentlemen:

I am familiar with the above-referenced Registration Statement filed by
RiverSource MVA Account (previously American Enterprise MVA Account) with the
Securities and Exchange Commission.

I have made such examination of law and examined such documents and records as
in my judgment are necessary and appropriate to enable me to give the following
opinion:

1.  The Company is duly incorporated, validly existing and in good standing
    under applicable state law and is duly licensed or qualified to do business
    in each jurisdiction where it transacts business.  The Company has all
    corporate powers required to carry on its business and to issue the
    contracts.

2.  The Account is a validly created and existing separate account of the
    Company and is duly authorized to issue the securities registered.

3.  The contracts issued by the Company, when offered and sold in accordance
    with the prospectus contained in the Registration Statement and in
    compliance with applicable law, will be legally issued and represent binding
    obligations of the Company in accordance with their terms.

I hereby consent to the filing of this opinion as an exhibit to the Registration
Statement.

Sincerely,


/s/ Mary Ellyn Minenko
- ----------------------
    Mary Ellyn Minenko
    Assistant General Counsel