Supplement to Prospectuses Dated May 1, 2006
Supplement dated November 20, 2006

Supplement dated November 20, 2006 to the May 1, 2006 Prospectuses for the
following annuity products: American Skandia Advisor Plan/SM/ III, American
Skandia APEX(R) II, American Skandia XTra Credit/SM/ SIX and American Skandia
LifeVest(R) II, as previously supplemented (the "Prospectuses").

This Supplement should be read and retained with the current Prospectus for
your annuity contract issued by American Skandia Life Assurance Corporation
("American Skandia"). This Supplement is intended to update certain information
in the Prospectus for the variable annuity you own, and is not intended to be a
prospectus or offer for any other variable annuity listed here that you do not
own. If you would like another copy of the current Prospectus, please contact
American Skandia at 1-800-752-6342.

We are issuing this supplement to describe in the Prospectus for the
above-referenced annuity products a new living benefit program, a change to the
CDSC schedule with respect to American Skandia XTra Credit SIX and certain
changes to the underlying mutual funds. These changes will be effective on or
about November 20, 2006, unless specifically stated otherwise.

1. NEW INSURANCE FEATURE

We are adding the Highest Daily Lifetime Five/SM/ Income Benefit ("Highest
Daily Lifetime Five"), that guarantees until the death of a single
designated life the ability to withdraw an annual amount equal to a
percentage of an initial principal value regardless of the impact of
market performance on the Account Value. As a result, the following
revisions are made to the Prospectus:

A. We revise the Glossary of Terms section as follows:

. We add a definition for "Benefit Fixed Rate Account", that reads as
follows: "An investment option offered as part of this Annuity that is
used only if you have elected the optional Highest Daily Lifetime Five
Benefit. Amounts allocated to the Benefit Fixed Rate Account earn a
fixed rate of interest, and are held within our general account. You
may not allocate purchase payments to the Benefit Fixed Rate Account.
Rather, Account Value is transferred to the Benefit Fixed Rate Account
only under the asset transfer feature of the Highest Daily Lifetime
Five Benefit."
. We add a definition for "Highest Daily Lifetime Five Benefit" that
reads as follows: "An optional feature available for an additional
charge that guarantees your ability to withdraw amounts equal to a
percentage of a principal value called the Protected Withdrawal Value.
Subject to our rules regarding the timing and amount of withdrawals,
we guarantee these withdrawal amounts, regardless of the impact of
market performance on your Account Value."

B. The following information has been added to "YOUR OPTIONAL BENEFIT
FEES AND CHARGES" table in the "Summary of Contract Fees and Charges"
section of the Prospectus:

TOTAL TOTAL TOTAL TOTAL
OPTIONAL ANNUAL ANNUAL ANNUAL ANNUAL
BENEFIT CHARGE CHARGE CHARGE CHARGE
FEE/ for for for for
CHARGE ASAPIII* APEX II* ASL II* XT6*
---------- ----------- -------- ------- ------------

HIGHEST DAILY LIFETIME FIVE INCOME BENEFIT**
0.60% of 1.85% in 2.25% 2.25% 2.25% in
average Annuity Annuity
daily Years 1-8; Years 1-10;
net assets 1.25% in 1.25% in
of Annuity Annuity
the Sub- Years 9 and Years 11 and
accounts later later

* The Total Annual Charge includes the Insurance Charge and Distribution Charge
(if applicable) assessed against the average daily net assets allocated to the
Sub-accounts. If you elect more than one optional benefit, the Total Annual
Charge would be increased to include the charge for each optional benefit.
** This optional benefit is not available under the Qualified BCO.

C. The Highest Daily Lifetime Five program is not available if you elect
any other optional living benefit, therefore all references in the
Prospectus that reflect the availability of the optional living
benefits are revised accordingly.

D. The following description of the new optional living benefit is added
as the last section under "Living Benefit Programs" in the Prospectus:

HIGHEST DAILY LIFETIME FIVE INCOME BENEFIT
(HIGHEST DAILY LIFETIME FIVE)

The Highest Daily Lifetime Five program described below is only being offered
in those jurisdictions where we have received regulatory approval and will be
offered subsequently in other jurisdictions when we receive regulatory approval
in those jurisdictions. Certain terms and conditions may differ between
jurisdictions once approved. Highest Daily Lifetime Five is offered as an
alternative to Lifetime Five and Spousal Lifetime Five. Currently, if you elect
Highest Daily Lifetime Five and subsequently terminate the benefit, you will
not be able to re-elect Highest Daily Lifetime Five, and will have a waiting
period until you can elect Spousal Lifetime Five or Lifetime Five.
Specifically, you will be permitted to elect Lifetime Five or Spousal Lifetime
Five only on an anniversary of the Issue Date that is at least 90 calendar days
from the date that Highest Daily Lifetime Five was terminated. We reserve the
right to further limit the election frequency in the future. The income benefit
under Highest Daily Lifetime Five currently is based on a single "designated
life" who is at least 55 years old on the date that the benefit is acquired.
The Highest Daily Lifetime Five Benefit is not available if you elect any other
optional living benefit, although you may elect any optional death benefit
(other than the Highest Daily Value Death Benefit). As long as your Highest
Daily Lifetime Five Benefit is in effect, you must allocate your Account Value
in accordance with the then-permitted and available investment option(s) with
this program.

We offer a benefit that guarantees until the death of the single designated
life the ability to withdraw an annual amount (the "Highest Daily Life Income
Benefit") equal to a percentage of an initial principal value (the "Protected
Withdrawal Value") regardless of the impact of market performance on the
Account Value, subject to our program rules regarding the timing and amount of
withdrawals. The benefit may be appropriate if you intend to make periodic
withdrawals from your Annuity, and wish to ensure that market performance will
not affect your ability to receive annual payments. You are not required to
make withdrawals as part of the program -- the guarantees are not lost if you
withdraw less than the maximum allowable amount each year under the rules of
the benefit. We discuss Highest Daily Lifetime Five in greater detail
immediately below. In addition, please see the Glossary section of this
prospectus for definitions of some of the key terms used with this benefit. As
discussed below, we require that you participate in our asset transfer program
in order to participate in Highest Daily Lifetime Five, and in the Appendices
to this prospectus, we set forth the formula under which we make those asset
transfers.

As discussed below, a key component of Highest Daily Lifetime Five is the
Protected Withdrawal Value, which is an amount that is distinct from Account
Value. Protected Withdrawal Value is used to determine the Highest Daily Annual
Income Amount -- which is an amount that you can take out annually as a
withdrawal for your entire life. Because each of the Protected Withdrawal Value
and Highest Daily Annual Income Amount is determined in a way that is not
solely related to Account Value, it is possible for the Account Value to fall
to zero, even though the Highest Daily Annual Income Amount remains. You are
guaranteed to be able to withdraw the Highest Daily Annual Income Amount for
the rest of your life, provided that you have not made "excess withdrawals."
Excess withdrawals, as discussed below, will reduce your Highest Daily Annual
Income Amount. Thus, you could experience a scenario in which your Account
Value was zero, and, due to your excess withdrawals, your Highest Daily Annual
Income Amount also was reduced to zero. In that scenario, no further amount
would be payable under Highest Daily Lifetime Five.

KEY FEATURE -- Protected Withdrawal Value
The Protected Withdrawal Value is used to determine the amount of the annual
payments under the Highest Daily Life Income Benefit. The Protected Withdrawal
Value initially is equal to the Account Value on the date that you elect
Highest Daily Lifetime Five. On each business day thereafter, until the earlier
of the first withdrawal or ten years after the date of your election of the
benefit, we recalculate the Protected Withdrawal Value. Specifically, on each
such business day (the "Current Valuation Day"), the Protected Withdrawal Value
is equal to the greater of:

. the Protected Withdrawal Value for the immediately preceding
business day (the "Prior Valuation Day"), appreciated at the daily
equivalent of 5% annually during the calendar day(s) between the
Prior Valuation Day and the Current Valuation Day (i.e., one day
for successive business days, but more than one calendar day for
business days that are separated by weekends and/or holidays), plus
the amount of any Purchase Payment (including any associated credit
with respect to XT6) made on the Current Valuation Day; and
. the Account Value.

We cease these daily calculations of the Protected Withdrawal Value when you
make your first withdrawal. However, as discussed below, subsequent Purchase
Payments (and any associated credits for XT6 only) will increase the amount we
guarantee to pay annually under the Highest Daily Life Income Benefit (the
"Highest Daily Annual Income Amount"), while "excess" withdrawals (as described
below) may decrease the Highest Daily Annual Income Amount.

KEY FEATURE -- Highest Daily Annual Income Amount under the Highest Daily
Lifetime Five Benefit
The initial Highest Daily Annual Income Amount is equal to 5% of the Protected
Withdrawal Value. Under the Highest Daily Lifetime Five benefit, if your
cumulative withdrawals in an Annuity Year are less than or equal to the Highest
Daily Annual Income Amount, they will not reduce your Highest Daily Annual
Income Amount in subsequent Annuity Years, but any such withdrawals will reduce
the Highest Daily Annual Income Amount on a dollar-for-dollar basis in that
Annuity Year. If your cumulative withdrawals

are in excess of the Highest Daily Annual Income Amount ("Excess Income"), your
Highest Daily Annual Income Amount in subsequent years will be reduced (except
with regard to required minimum distributions) by the result of the ratio of
the Excess Income to the Account Value immediately prior to such withdrawal
(see examples of this calculation below). Reductions include the actual amount
of the withdrawal, including any CDSC that may apply. A Purchase Payment that
you make will increase the then-existing Highest Daily Annual Income Amount by
an amount equal to 5% of the Purchase Payment (including, with respect to XT6,
the amount of any associated Credits).

An automatic step-up feature ("Highest Quarterly Auto Step-Up") is included as
part of this benefit. As detailed in this paragraph, the Highest Quarterly Auto
Step-Up feature can result in a larger Highest Daily Annual Income Amount if
your Account Value increases subsequent to your first withdrawal. We begin
examining the Account Value for purposes of this feature starting with the
anniversary of the Issue Date of the Annuity (the "Annuity Anniversary")
immediately after your first withdrawal under the benefit. Specifically, upon
the first such Annuity Anniversary, we identify the Account Value on the
business days corresponding to the end of each quarter that (i) is based on
your Annuity Year, rather than a calendar year; (ii) is subsequent to the first
withdrawal; and (iii) falls within the immediately preceding Annuity Year. If
the end of any such quarter falls on a holiday or a weekend, we use the next
business day. We multiply each of those quarterly Account Values by 5%, adjust
each such quarterly value for subsequent withdrawals and purchase payments, and
then select the highest of those values. If the highest of those values exceeds
the existing Highest Daily Annual Income Amount, we replace the existing amount
with the new, higher amount. Otherwise, we leave the existing Highest Daily
Annual Income Amount intact. In later years, (i.e., after the first Annuity
Anniversary after the first withdrawal) we determine whether an automatic
step-up should occur on each Annuity Anniversary, by performing a similar
examination of the Account Values on the end of the four immediately preceding
quarters. If, on the date that we implement a Highest Quarterly Auto Step-Up to
your Highest Daily Annual Income Amount, the charge for Highest Daily Lifetime
Five has changed for new purchasers, you may be subject to the new charge at
the time of such step-up. Prior to increasing your charge for Highest Daily
Lifetime Five upon a step-up, we would notify you, and give you the opportunity
to cancel the automatic step-up feature.

The Highest Daily Lifetime Five program does not affect your ability to make
withdrawals under your annuity, or limit your ability to request withdrawals
that exceed the Highest Daily Annual Income Amount. Under Highest Daily
Lifetime Five, if your cumulative withdrawals in an Annuity Year are less than
or equal to the Highest Daily Annual Income Amount, they will not reduce your
Highest Daily Annual Income Amount in subsequent Annuity Years, but any such
withdrawals will reduce the Highest Daily Annual Income Amount on a
dollar-for-dollar basis in that Annuity Year.

If, cumulatively, you withdraw an amount less than the Highest Daily Annual
Income Amount in any Annuity Year, you cannot carry-over the unused portion of
the Highest Daily Annual Income Amount to subsequent Annuity Years.

Examples of dollar-for-dollar and proportional reductions, and the Highest
Quarterly Step-Up are set forth below. The values depicted here are purely
hypothetical, and do not reflect the charges for the Highest Daily Lifetime
Five benefit or any other fees and charges. Assume the following for all three
examples:

. The Issue Date is December 1, 2006
. The Highest Daily Lifetime Five benefit is elected on March 5, 2007.

Dollar-for-dollar reductions
On May 2, 2007, the Protected Withdrawal Value is $120,000, resulting in a
Highest Daily Annual Income Amount of $6,000 (5% of $120,000). Assuming $2,500
is withdrawn from the Annuity on this date, the remaining Highest Daily Annual
Income Amount for that Annuity Year (up to and including December 1, 2007) is
$3,500. This is the result of a dollar-for-dollar reduction of the Highest
Daily Annual Income Amount -- $6,000 less $2,500 = $3,500.

Proportional reductions
Continuing the previous example, assume an additional withdrawal of $5,000
occurs on August 6, 2007 and the Account Value at the time of this withdrawal
is $110,000. The first $3,500 of this withdrawal reduces the Highest Daily
Annual Income Amount for that Annuity Year to $0. The remaining withdrawal
amount -- $1,500 - reduces the Highest Daily Annual Income Amount in future
Annuity Years on a proportional basis based on the ratio of the excess
withdrawal to the Account Value immediately prior to the excess withdrawal.
(Note that if there were other withdrawals in that Annuity Year, each would
result in another proportional reduction to the Highest Daily Annual Income
Amount).

Here is the calculation:

Account Value before withdrawal $110,000.00
Less amount of "non" excess withdrawal -$ 3,500.00
Account Value immediately before excess withdrawal of $1,500 $106,500.00
Excess withdrawal amount $ 1,500.00
Divided by Account Value immediately before excess withdrawal $106,500.00
Ratio 1.41%

Annual Income Amount $ 6,000.00
Less ratio of 1.41% -$ 84.51
Annual Income Amount for future Annuity Years $ 5,915.49

Highest Quarterly Step-Up

On each Annuity Anniversary date, the Highest Daily Annual Income Amount is
stepped-up if 5% of the highest quarterly value since your first withdrawal (or
last Annuity Anniversary in subsequent years), adjusted for excess withdrawals
and additional Purchase Payments, is higher than the Highest Daily Annual
Income Amount, also adjusted for excess withdrawals and additional Purchase
Payments.

Continuing the same example as above, the Highest Daily Annual Income Amount
for this Annuity Year is $6,000. However, the excess withdrawal on August 6
reduces this amount to $5,915.49 for future years (see above). For the next
Annuity Year, the Highest Daily Annual Income Amount will be stepped-up if 5%
of the highest quarterly Account Value, adjusted for withdrawals, is higher
than $5,915.49. Here are the calculations for determining the quarterly values.
Only the June 1 value is being adjusted for excess withdrawals as the
September 1 and December 1 Valuation Days occur after the excess withdrawal on
August 6.

Highest Quarterly Value Adjusted Highest Daily
(adjusted with Annual Income Amount (5%
withdrawal and Purchase of the Highest Quarterly
Date* Account value Payments)** Value)
----- ------------- ----------------------- ------------------------

June 1, 2007 $118,000.00 $118,000.00 $5,900.00
August 6, 2007 $120,000.00 $112,885.55 $5,644.28
September 1, 2007 $112,000.00 $112,885.55 $5,644.28
December 1, 2007 $119,000.00 $119,000.00 $5,950.00

*In this example, the Annuity Anniversary date is December 1. The quarterly
valuation dates are every three months thereafter -
March 1, June 1, September 1, and December 1. In this example, we do not use
the March 1 date as the first withdrawal took place after March 1. The Annuity
Anniversary Date of December 1 is considered the fourth and final quarterly
valuation date for the year.

**In this example, the first quarterly value after the first withdrawal is
$118,000 on June 1, yielding an adjusted Highest Daily Annual Income Amount of
$5,900.00. This amount is adjusted on August 6 to reflect the $5,000
withdrawal. The calculations for the adjustments are:
. The Account Value of $118,000 on June 1 is first reduced
dollar-for-dollar by $3,500 ($3,500 is the remaining Highest Daily
Annual Income Amount for the Annuity Year), resulting in an adjusted
Account Value of $114,500 before the excess withdrawal.
. This amount ($114,500) is further reduced by 1.41% (this is the ratio
in the above example which is the excess withdrawal divided by the
Account Value immediately preceding the excess withdrawal) resulting
in a Highest Quarterly Value of $112,885.55.

The adjusted Highest Daily Annual Income Amount is carried forward to the next
quarterly anniversary date of September 1. At this time, we compare this amount
to 5% of the Account Value on September 1. Since the June 1 adjusted Highest
Daily Annual Income Amount of $5,644.28 is higher than $5,600.00 (5% of
$112,000), we continue to carry $5,644.28 forward to the next and final
quarterly anniversary date of December 1. The Account Value on December 1 is
$119,000 and 5% of this amount is $5,950. Since this is higher than $5,644.28,
the adjusted Highest Daily Annual Income Amount is reset to $5,950.00

In this example, 5% of the December 1 value yields the highest amount of $
5,950.00. Since this amount is higher than the current year's Highest Daily
Annual Income Amount of $5,915.49 adjusted for excess withdrawals, the Highest
Daily Annual Income Amount for the next Annuity Year, starting on December 2,
2007 and continuing through December 1, 2008, will be stepped-up to $5,950.00.

BENEFITS UNDER THE HIGHEST DAILY LIFETIME FIVE PROGRAM
. To the extent that your Account Value was reduced to zero as a result
of cumulative withdrawals that are equal to or less than the Highest
Daily Annual Income Amount and amounts are still payable under the
Highest Daily Life Income Benefit, we will make an additional payment,
if any, for that Annuity Year equal to the remaining Highest Daily
Annual Income Amount for the Annuity Year. Thus, in that scenario, the
remaining Highest Daily Annual Income Amount would be payable even
though your Account Value was reduced to zero. In subsequent Annuity
Years we make payments that equal the Highest Daily Annual Income
Amount as described in this section. We will make payments until the
death of the single designated life. To the extent that cumulative
withdrawals in the current Annuity Year that reduced your Account
Value to zero are more

than the Highest Daily Annual Income Amount, the Highest Daily
Lifetime Five benefit terminates, and no additional payments will be
made.

. If Annuity payments are to begin under the terms of your Annuity, or
if you decide to begin receiving Annuity payments and there is a
Highest Daily Annual Income Amount due in subsequent Annuity Years,
you can elect one of the following two options:

(1) apply your Account Value to any Annuity option available; or
(2) request that, as of the date Annuity payments are to begin, we
make Annuity payments each year equal to the Highest Daily Annual
Income Amount. We will make payments until the death of the single
designated life.

We must receive your request in a form acceptable to us at our office.

In the absence of an election when mandatory annuity payments are to begin, we
will make annual annuity payments in the form of a single life fixed annuity
with ten payments certain, by applying the greater of the annuity rates then
currently available or the annuity rates guaranteed in your Annuity. The amount
that will be applied to provide such Annuity payments will be the greater of:

(1) the present value of the future Highest Daily Annual Income
Amount payments. Such present value will be calculated using the greater of the
single life fixed annuity rates then currently available or the single life
fixed annuity rates guaranteed in your Annuity; and
(2) the Account Value.

. If no withdrawal was ever taken, we will determine the Protected
Withdrawal Value and calculate the Highest Daily Annual Income Amount
as if you made your first withdrawal on the date the annuity payments
are to begin.

Other Important Considerations
. Withdrawals under the Highest Daily Lifetime Five benefit are subject
to all of the terms and conditions of the Annuity, including any CDSC.
. Withdrawals made while the Highest Daily Lifetime Five program is in
effect will be treated, for tax purposes, in the same way as any other
withdrawals under the Annuity. The Highest Daily Lifetime Five program
does not directly affect the Account Value or surrender value, but any
withdrawal will decrease the Account Value by the amount of the
withdrawal (plus any applicable CDSC). If you surrender your Annuity
you will receive the current surrender value.
. You can make withdrawals from your Annuity while your Account Value is
greater than zero without purchasing the Highest Daily Lifetime Five
benefit. The Highest Daily Lifetime Five benefit provides a guarantee
that if your Account Value declines due to market performance, you
will be able to receive your Highest Daily Annual Income Amount in the
form of periodic benefit payments. You must allocate your Account
Value in accordance with the then available investment option(s) that
we may permit in order to elect and maintain the Highest Daily
Lifetime Five benefit.

Election of and Designations under the Program
For Highest Daily Lifetime Five, there must be either a single Owner who is the
same as the Annuitant, or if the Annuity is entity-owned, there must be a
single natural person Annuitant. In either case, the Annuitant must be at least
55 years old.

Any change of the Annuitant under the Annuity will result in cancellation of
Highest Daily Lifetime Five. Similarly, any change of Owner will result in
cancellation of Highest Daily Lifetime Five, except if (a) the new Owner has
the same taxpayer identification number as the previous owner (b) both the new
Owner and previous Owner are entities or (c) the previous Owner is a natural
person and the new Owner is an entity.

Highest Daily Lifetime Five can be elected at the time that you purchase your
Annuity. However, with respect to XT6, you may elect this benefit at the time
you purchase your Annuity only if the CDSC schedule for XT6 Annuities issued on
or after November 20, 2006 applies. (See "Summary of Contract Fees and Charges"
section of the Prospectus and section 2 of this Supplement). We also offer
existing owners (i.e., those who have already acquired their Annuity) the
option to elect Highest Daily Lifetime Five after the Issue Date, subject to
our eligibility rules and restrictions. However, for existing Owners of XT6
whose Annuities are subject to the CDSC schedule for Annuities issued prior to
November 20, 2006, this benefit may only be elected on or after the first
anniversary of the Issue Date.

Currently, if you terminate the Highest Daily Lifetime Five benefit, you will
(a) not be permitted to re-elect the benefit and (b) will be allowed to elect
the Spousal Lifetime Five Benefit or the Lifetime Five Income Benefit on any
anniversary of the Issue Date that is at least 90 calendar days from the date
the Highest Daily Lifetime Five Benefit was terminated. We reserve the right to
further limit the election frequency in the future. Before making any such
change to the election frequency, we will provide prior notice to Owners who
have an effective Highest Daily Lifetime Five benefit.

Termination of the Program
You may terminate the benefit at any time by notifying us. If you terminate the
benefit, any guarantee provided by the benefit will terminate as of the date
the termination is effective, and certain restrictions on re-election will
apply as described above. We reserve the right to further limit the frequency
election in the future. The benefit terminates: (i) upon your termination of
the benefit (ii) upon your surrender of the Annuity (iii) upon your election to
begin receiving annuity payments (iv) upon the death of the designated life
(v) if both the Account Value and Highest Daily Annual Income Amount equal zero
or (vi) if you fail to meet our requirements for issuing the benefit.

Upon termination of Highest Daily Lifetime Five, we cease deducting the charge
for the benefit. With regard to your investment allocations, upon termination
we will: (i) leave intact amounts that are held in the variable investment
options, and (ii) transfer all amounts held in the Benefit Fixed Rate Account
(as defined below) to your variable investment options, based on your existing
allocation instructions or (in the absence of such existing instructions) pro
rata (i.e. in the same proportion as the current balances in your variable
investment options).

Asset Transfer Component of Highest Daily Lifetime Five

As indicated above, we limit the sub-accounts to which you may allocate Account
Value if you elect Highest Daily Value Lifetime Five. For purposes of this
benefit, we refer to those permitted sub-accounts as the "Permitted
Sub-accounts". As a requirement of participating in Highest Daily Lifetime
Five, we require that you participate in our specialized asset transfer
program, under which we may transfer Account Value between the Permitted
Sub-accounts and a fixed interest rate account that is part of our general
account (the "Benefit Fixed Rate Account"). We determine whether to make a
transfer, and the amount of any transfer, under a non-discretionary formula,
discussed below. The Benefit Fixed Rate Account is available only with this
benefit, and thus you may not allocate purchase payments to that Account.

Under the asset transfer component of Highest Daily Lifetime Five, we monitor
your Account Value daily and, if necessary, systematically transfer amounts
between the Permitted Sub-accounts you have chosen and the Benefit Fixed Rate
Account. Any transfer would be made in accordance with a formula, which is set
forth in the schedule supplement to the endorsement for this benefit (and also
appears in the Appendices to this prospectus). Specifically, each business day,
the formula monitors fluctuations in your Account Value, your projected Highest
Daily Annual Income Amount, and other factors, relative to certain
"reallocation triggers" to determine whether Account Value must be transferred
to or from the Benefit Fixed Rate Account. As you can glean from the formula
itself, a downturn in the securities markets that equals or exceeds the
reallocation trigger level will cause us to transfer some of your Account Value
to the Benefit Fixed Rate Account. Moreover, certain market return scenarios
involving "flat" returns over a period of time also could result in the
transfer of money to the Benefit Fixed Rate Account. In deciding how much to
transfer, we look at a number of factors, including the severity of the decline
and, based on current values, how much we would be obligated to pay out if you
withdrew the Highest Daily Annual Income Amount each year for the remainder of
your life. Conversely, appreciation in the securities markets that affects your
Account Value may cause us to transfer Account Value from the Benefit Fixed
Rate Account to your Permitted Sub-Accounts. As with a decline, the amount that
we transfer will depend on a number of factors, including the magnitude of the
increase and our estimate of the cumulative Highest Daily Annual Income Amounts
that we would pay out over your lifetime.

While you are not notified when your Annuity reaches a reallocation trigger,
you will receive a confirmation statement indicating the transfer of a portion
of your Account Value either to or from the Benefit Fixed Rate Account. The
formula by which the reallocation triggers operate is designed primarily to
mitigate the financial risks that we incur in providing the guarantee under
Highest Daily Lifetime Five.

Depending on the results of the calculation relative to the reallocation
triggers, we may, on any day:

. Not make any transfer; or
. If a portion of your Account Value was previously allocated to the
Benefit Fixed Rate Account, transfer all or a portion of those amounts
to the Permitted Sub-accounts, based on your existing allocation
instructions or (in the absence of such existing instructions) pro
rata (i.e., in the same proportion as the current balances in your
variable investment options). Amounts taken out of the Benefit Fixed
Rate Account will be withdrawn for this purpose on a last-in,
first-out basis (an amount renewed into a new guarantee period under
the Benefit Fixed Rate Account will be deemed a new investment for
purposes of this last-in, first-out rule); or
. Transfer all or a portion of your Account Value in the Permitted
Sub-accounts pro-rata to the Benefit Fixed Rate Account. The interest
that you earn on such transferred amount will be equal to the annual
rate that we have set for that day, and we will credit the daily
equivalent of that annual interest until the earlier of one year from
the date of the transfer or the date that such amount in the Benefit
Fixed Rate Account is transferred back to the Permitted Sub-accounts.

If a significant amount of your Account Value is systematically transferred to
the Benefit Fixed Rate Account during periods of market declines or low
interest rates, less of your Account Value may be available to participate in
the investment experience of the

Permitted Sub-accounts if there is a subsequent market recovery. Under the
reallocation formula that we employ, it is possible that a significant portion
of your Account Value may be allocated to the Benefit Fixed Rate Account.

Additional Tax Considerations for Qualified Contracts

If you purchase an annuity as an investment vehicle for "qualified"
investments, including an IRA, SEP-IRA, Tax Sheltered Annuity (or 403(b)) or
employer plan under Code Section 401(a), the minimum distribution rules under
the Code require that you begin receiving periodic amounts from your annuity
beginning after age 70 1/2. For a Tax Sheltered Annuity or a 401(a) plan for
which the participant is not a greater than 5 percent owner of the employer,
this required beginning date can generally be deferred to retirement, if later.
Roth IRAs are not subject to these rules during the owner's lifetime. The
amount required under the Code may exceed the Highest Daily Annual Income
Amount, which will cause us to increase the Highest Daily Annual Income Amount
in any Annuity Year that required minimum distributions due from your Annuity
that are greater than such amounts. In addition, the amount and duration of
payments under the annuity payment and death benefit provisions may be adjusted
so that the payments do not trigger any penalty or excise taxes due to tax
considerations such as minimum distribution requirements.

2. CHANGE TO THE CDSC SCHEDULE WITH RESPECT TO XT6

A. The list of the "CONTINGENT DEFERRED SALES CHARGES FOR EACH ANNUITY" in the
"Summary of Contract Fees and Charges" section of the Prospectus is replaced
with the following with regard to XT6:

For Annuities issued prior to November 20, 2006, the following schedule applies:

XT6
-----------------------------------------------------------------
Yr.1 Yr.2 Yr.3 Yr. 4 Yr. 5 Yr. 6 Yr. 7 Yr. 8 Yr. 9 Yr. 10 Yr. 11+
---- ---- ---- ----- ----- ----- ----- ----- ----- ------ -------
9.0% 9.0% 8.5% 8.0% 7.0% 6.0% 5.0% 4.0% 3.0% 2.0% 0.0%

For Annuities issued on or after November 20, 2006 (subject to state
availability), the following schedule applies*:

* In jurisdictions that have not yet approved this schedule, the schedule
for Annuities issued prior to November 20, 2006 will apply.

B. Under the "Expense Examples" section of the Prospectus, we add a
parenthetical after XT6 stating "(CDSC schedule for Annuities issued before
November 20, 2006)". In addition, we add a new line item as follows:

IF YOU SURRENDER YOUR ANNUITY IF YOU ANNUITIZE YOUR ANNUITY
AT THE END OF THE APPLICABLE AT THE END OF THE APPLICABLE IF YOU DO NOT SURRENDER
TIME PERIOD: TIME PERIOD: YOUR ANNUITY:
----------------------------- ----------------------------- -------------------------

XT6 (CDSC _ _ _ _ N/A N/A $3,026 $5,929 $615 $1,831 $3,026 $5,929
schedule for
Annuities issued on
or after November
20, 2006)

(additional expense example numbers to be provided in subsequent post-effective
amendment)

C. We revise Appendix F of the Prospectus entitled "Selecting the Variable
Annuity That's Right for You" as follows:

For XTra Credit SIX, we revise the entry entitled "Withdrawal Charge Schedule"
as follows: (9%,9%,8%,7%,6%,5%,4%,3%,2%,1% for Annuities issued on or after
November 20, 2006), and (9%, 9%, 8.5%, 8%, 7%, 6%, 5%, 4%, 3% 2% for Annuities
issued prior to November 20, 2006).

The 0 percent and 6 percent Gross Rate of Return columns for Xtra Credit SIX
assume the CDSC applicable to such Annuities sold prior to November 20, 2006.
In addition to those hypothetical values, we add these values, for Xtra Credit
SIX Annuities sold on or after November 20, 2006, which are subject to a
different CDSC schedule:

0% Gross Rate of Return

APEX II ASAP III Xtra Credit SIX ASL II
------------------ ------------------ ------------------ ------------------
Contract Surrender Contract Surrender Contract Surrender Contract Surrender
Yr Value Value Value Value Value Value Value Value
- -- -------- --------- -------- --------- -------- --------- -------- ---------
1 96,942 88,442 97,335 88,835 103,243 94,243 96,942 96,942
2 93,936 85,936 94,700 87,700 100,044 91,044 93,936 93,936
3 91,021 84,021 92,136 85,636 96,942 88,942 91,021 91,021
4 88,197 82,197 89,640 83,640 93,936 86,936 88,197 88,197
5 85,458 85,458 87,211 82,211 91,022 85,022 85,458 85,458
6 85,470 85,470 85,333 81,333 88,197 83,197 82,804 82,804
7 82,815 82,815 83,019 80,019 85,458 81,458 80,231 80,231
8 80,242 80,242 80,767 78,767 82,804 79,804 77,737 77,737
9 77,748 77,748 79,051 79,051 80,231 78,231 75,320 75,320
10 75,330 75,330 77,371 77,371 77,737 76,737 72,976 72,976
11 72,986 72,986 75,727 75,727 76,083 76,083 70,705 70,705
12 70,714 70,714 74,117 74,117 74,466 74,466 68,503 68,503
13 68,512 68,512 72,541 72,541 72,882 72,882 66,368 66,368
14 66,377 66,377 70,998 70,998 71,332 71,332 64299 64,299
15 64,308 64,308 69,486 69,486 69,813 69,813 62,294 62,294
16 62,302 62,302 68,006 68,006 68,326 68,326 60,350 60,350
17 60,358 60,358 66,557 66,557 66,871 66,871 58,465 58,465
18 58,473 58,473 65,138 65,138 65,445 65,445 56,639 56,639
19 56,647 56,647 63,748 63,748 64,049 64,049 54,868 54,868
20 54,876 54,876 62,387 62,387 62,682 62,682 53,152 53,152
21 53,159 53,159 61,055 61,055 61,344 61,344 51,488 51,488
22 51,495 51,495 59,751 59,751 60,033 60,033 49,876 49,876
23 49,882 49,882 58,473 58,473 58,750 58,750 48,312 48,312
24 48,319 48,319 57,222 57,222 57,493 57,493 46,797 46,797
25 46,803 46,803 55,997 55,997 56,263 56,263 45,328 45,328

Assumptions:
a. $100,000 initial investment
b. Fund Expenses = 1.44%
c. No optional death benefits or living benefits elected
d. Annuity was issued on or after November 20, 2006
e. Surrender value assumes surrender 2 days before policy anniversary

6% Gross Rate of Return

APEX II ASAP III Xtra Credit SIX ASL II
------------------ ------------------ ------------------ ------------------
Contract Surrender Contract Surrender Contract Surrender Contract Surrender
Yr Value Value Value Value Value Value Value Value
- -- -------- --------- -------- --------- -------- --------- -------- ---------
1 102,742 94,242 103,159 94,659 109,420 100,420 102,742 102,742
2 105,567 97,567 106,427 99,427 112,393 103,393 105,567 105,567
3 108,470 101,470 109,798 103,298 115,448 107,448 108,470 108,470
4 111,453 105,453 113,276 107,276 118,586 111,586 111,453 111,453
5 114,518 114,518 116,864 111,864 121,811 115,811 114,518 114,518
6 120,492 120,492 121,082 117,082 125,125 120,125 117,667 117,667
7 123,805 123,805 124,917 121,917 128,530 124,530 120,902 120,902
8 127,210 127,210 128,874 126,874 132,028 129,028 124,227 124,227
9 130,708 130,708 133,762 133,762 135,623 133,623 127,643 127,643
10 134,302 134,302 138,838 138,838 139,316 138,316 131,153 131,153
11 137,995 137,995 144,106 144,106 144,562 144,562 134,759 134,759
12 141,789 141,789 149,574 149,574 150,011 150,011 138,465 138465
13 145,688 145,688 155,250 155,250 155,667 155,667 142,272 142,272
14 149,694 149,694 161,141 161,141 161,537 161,537 146,184 146,184
15 153,811 153,811 167,255 167,255 167,631 167,631 150,204 150,204
16 158,040 158,040 173,602 173,602 173,955 173,955 154,334 154,334
17 162,386 162,386 180,189 180,189 180,520 180,520 158,578 158,578
18 166,851 166,851 187,027 187,027 187,333 187,333 162,939 162,939
19 171,439 171,439 194,123 194,123 194,405 194,405 167,419 167,419
20 176,153 176,153 201,489 201,489 201,746 201,746 172,023 172,023
21 180,997 180,997 209,135 209,135 209,365 209,365 176,753 176,753
22 185,974 185,974 217,071 217,071 217,273 217,273 181,613 181,613
23 191,088 191,088 225,307 225,307 225,481 225,481 186,607 186,607
24 196,343 196,343 233,857 233,857 234,000 234,000 191,739 191,739
25 201,742 201,742 242,730 242,730 242,843 242,843 197,011 197,011

Assumptions:

a. $100,000 initial investment
b. Fund Expenses = 1.44%
c. No optional death benefits or living benefits elected
d. Annuity was issued on or after November 20, 2006
e. Surrender value assumes surrender 2 days before policy anniversary

Finally, we replace each table that depicts the days in which each annuity
product would have the highest surrender value with the following:

In addition, the following charts indicate the days (measured from the Issue
Date) in which each annuity product would have the highest Surrender Value
amongst the products listed given the above assumptions.

0% Gross Rate of Return (After November 20, 2006)

Over 30 Years, days won
Total Days Year Actual Days
----------------------- ----- -----------
APEX II 4-5 1460-1824
1459 6-8 1826-2919
ASAP III 9 2936-3284
635 10 3364-3649
Xtra Credit SIX 5 1825
8-9 2920-2935
9-10 3285-3363
7397 10-30 3650-10950
ASL II 1824 1-5 1-1824

6% Gross Rate of Return (After November 20, 2006)

Over 30 Years, days won
Total Days Year Actual Days
----------------------- ----- -----------
APEX II 364 6 1826-2189
ASAP III 3245-3284
9 3511-3649
10 10220-
910 28-30 10950
Xtra Credit SIX 4-5 1205-1825
6-9 2190-3244
9-10 3245-3510
8472 10-28 3650-10219
ASL II 1204 1-4 1-1204

3. CHANGE WITH RESPECT TO CERTAIN PORTFOLIOS OF AMERICAN SKANDIA TRUST

In the "Investment Options" section of the prospectus, we make the following
changes to the chart setting forth a brief description of each variable
investment option, to reflect the following subadviser name change with respect
to one of the variable investment options:

.. AST Small Cap Value Portfolio. Salomon Brothers Asset Management will
change its name to ClearBridge Advisers LLC, effective in December 2006.

In the "Investment Options" section of each prospectus, we revise the
investment objectives/policies section, and portfolio advisor/sub-advisor
section for two Portfolios to read as follows. These new descriptions reflect
the addition of sub-advisors as well as revisions to non-fundamental investment
policies:

AST LSV International Value Portfolio.

PORTFOLIO
STYLE/ ADVISOR/
TYPE INVESTMENT OBJECTIVES/POLICIES SUB-ADVISOR
------ ---------------------------------------------------------- --------------------

International AST International Value Portfolio (formerly AST LSV LSV Asset
Equity International Value Portfolio): seeks capital growth. The Management,
Portfolio normally invests at least 80% of the Portfolio's Thornburg Investment
investable assets (net assets plus borrowings made for Management, Inc.
investment purposes) in the equity securities of
companies in developed countries outside the United
States that are represented in the MSCI EAFE Index.

AST William Blair International Growth Portfolio.

PORTFOLIO
STYLE/ ADVISOR/
TYPE INVESTMENT OBJECTIVES/POLICIES SUB-ADVISOR
------ ---------------------------------------------------------- ---------------

International AST International Growth Portfolio (formerly,AST Marsico Capital
Equity William Blair International Growth Portfolio): seeks Management LLC,
long-term capital appreciation. The Portfolio invests William Blair &
primarily in equity-related securities of foreign issuers. Company, LLC
The Portfolio invests primarily in the common stock of
large and medium-sized foreign companies, although it
may also invest in companies of all sizes. Under normal
circumstances, the Portfolio invests at least 65% of its
total assets in common stock of foreign companies
operating or based in at least five different countries,
which may include countries with emerging markets. The
Portfolio looks primarily for stocks of companies whose
earnings are growing at a faster rate than other
companies or which offer attractive growth potential.

4. WE ADD THE FOLLOWING AS APPENDIX G:

Appendix G

Asset Transfer Formula Under Highest Daily Lifetime Five Benefit

We set out below the current formula under which we may transfer amounts
between the variable investment options and the Benefit Fixed Rate Account. As
discussed in the "Living Benefits" section, we reserve the right to modify this
formula with respect to those who elect Highest Daily Lifetime Five in the
future. However, upon your election of Highest Daily Lifetime Five, we will not
alter the asset transfer formula that applies to your Annuity.

Terms and Definitions referenced in the calculation formula:
. C\\u\\ - the upper target is established on the Effective Date and is not
changed for the life of the guarantee.
. C\\t\\ - the target is established on the Effective Date and is not
changed for the life of the guarantee.
. C\\l\\ - the lower target is established on the Effective Date and is not
changed for the life of the guarantee.
. L - the target value as of the current Valuation Day.
. r - the target ratio.
. a - the factors used in calculating the target value. These factors are
established on the Effective Date and are not changed for the life of the
guarantee.
. Q - age based factors used in calculating the target value. These factors
are established on the Effective Date and are not changed for the life of
the guarantee.
. V - the total value of all Sub-accounts in the Annuity.
. F - the total value of all Benefit Fixed Rate Account allocations.
. I - the Income Value prior to the first withdrawal. The Income Value is
equal to what the Annual Income Amount would be if the first withdrawal
were taken on the date of calculation. After the first withdrawal the
Income Value equals the greater of the Annual Income Amount, the
quarterly step-up amount times the Annual Income Percentage, and the
Account Value times the Annual Income Percentage.
. T - the amount of a transfer into or out of the Benefit Fixed Rate
Account.
. I% - Annual Income Amount percentage. This factor is established on the
Effective Date and is not changed for the life of the guarantee.

Target Value Calculation:
On each Valuation Day, a target value (L) is calculated, according to the
following formula. If the variable Account Value (V) is equal to zero, no
calculation is necessary.

L = I * Q * a

Transfer Calculation:
The following formula, which is set on the Effective Date and is not changed
for the life of the guarantee, determines when a transfer is required:

Target Ratio r = (L - F) / V.
. If r (greater than) C\\u\\, assets in the Sub-accounts are
transferred to Benefit Fixed Rate Account.
. If r (less than) C\\l\\, and there are currently assets in the Benefit
Fixed Rate Account (F (greater than) 0), assets in the Benefit Fixed
Rate Account are transferred to the Sub-accounts.

The following formula, which is set on the Effective Date and is not changed
for the life of the guarantee, determines the transfer amount:

T ={Min(V, [L - F - V * C\\t\\] / (1-C\\t\\))} T(greater than)0, Money moving from the Sub-accounts to the Benefit
Fixed Rate Account
T ={Min(F, [L - F - V * C\\t\\] / (1-C\\t\\))} T(less than)0, Money moving from the Benefit Fixed Rate Account to
the Sub-accounts]

September 12, 2006

Ms. Sally Samuel, Esq.
Office of Insurance Products
Division of Investment Management
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549

RE: Responses to your comments to Post-effective amendment under Rule 485(a)
under the Securities Act of 1933 to Form N-4 registration statement, file no.
333-96577

Dear Ms. Samuel:

As you know, last July we filed a post-effective amendment under Rule 485(a) to
the above-referenced registration statement to add a new living benefit called
"Highest Daily Lifetime Five" (the "Benefit"). In this filing, we respond to
your comments on the Rule 485(a) filing we made in July. We also enclose a copy
of the revised draft supplement for your review.

We set out below your comments and our responses thereto.

1. Comment: You requested that in the section of the supplement that
discusses the Benefit, we describe in more detail how the asset
transfer formula operates. In addition, you asked that the formula
itself be set forth in the prospectus. Finally, you asked that we
disclose that the formula applicable to a given annuity owner who
selects the Benefit cannot be changed for that owner.

Response: We have expanded our discussion of the Benefit formula in the section
of the supplement entitled "Asset Transfer Component of Highest Daily Lifetime
Five", and have set forth the formula itself in a new appendix to the
prospectus. Please note that we have excluded from what is set forth in the
appendix certain aspects of the formula's operation that are proprietary. The
formula, as it appears in the appendix, is the same as what we set forth in the
schedule supplement to the annuity contract. We think that what we propose to
set forth in the appendix will provide investors with a good sense of how the
formula works.

2. Comment: You asked that we add disclosure to clarify how long an
annuity owner who has terminated the benefit must wait before electing
Lifetime Five or Spousal Lifetime Five.

Response: We have added that disclosure.

3. Comment: You asked that in the summary paragraph beginning with "We
offer a benefit . . ."), we cross reference other key sections that
provide greater detail about the Benefit. You also asked that we
discuss in more detail which benefits remain in effect if the contract
value becomes zero.

Response: We have added clarifying disclosure.

4. Comment: With regard to the mathematical examples in the supplement,
you asked us to explain the relevance of the March 5, 2007 date and
the May 2, 2007 date. You also asked us to add disclosure explaining
that a proportional reduction can occur more than once.

Response: March 5, 2007 is the date that the Benefit is elected. May 2, 2007 is
the date of the first withdrawal. Thus, it is on May 2, 2007 that the amount of
the Protected Withdrawal Value is "locked in." With regard to your other
comment, we have added clarifying disclosure.

5. Comment: With regard to the section concerning the Highest Quarterly
Auto- Step-Up, you asked us to clarify the reference to "later years",
and to indicate how often the auto-step calculation is done.

Response: We have added disclosure clarifying the reference to "later years."
As indicated in the current draft supplement, we determine whether an auto-step
up occurs "on each contract anniversary."

6. Comment: You asked about the "default" annuity option that is
associated with the Benefit. In addition, you asked whether a variable
annuity payout option is available.

Response: As indicated in the current draft supplement, in the absence of an
election when mandatory annuity payments are to begin, we will make annual
annuity payments in the form of a single life fixed annuity with ten payments
certain. Because there are ten years' worth of payments guaranteed, it is not
possible for the payee to receive only one payment. With regard to this annuity
product, we offer only fixed annuity payout options --- not variable annuity
payout options. Variable annuity payout options are only offered through a
separate contract and prospectus.

7. Comment: In the section entitled "Elections of and Designations Under
the Benefit", you asked us to clarify that in-force contracts can
elect the Benefit.

Response: We have added clarifying disclosure.

8. Comment: In certain sections of the supplement, you asked us to
clarify the distinction between "existing allocation instructions" and
"otherwise pro rata".

Response: We have made that clarification.

9. Comment: You asked us to clarify the disclosure that the Benefit can
be purchased post issue.

Response: We have made that clarification.

We represent and acknowledge that:

. the depositor and the registrant are responsible for the adequacy and
accuracy of the disclosure in the instant filing; and
. staff comments, or changes to disclosure in response to staff comments
in the filings reviewed by the staff, do not foreclose the Commission
from taking any action with respect to the instant filing; and
. the depositor and the registrant may not assert staff comments as a
defense in any proceeding initiated by the Commission or any person
under the federal securities laws of the United States.

If these responses are acceptable to you, we will make the changes in 485(b)
filings for the ASLAC variable annuity products that were made last July. We
appreciate your attention to this filing.

Sincerely,

Laura K. Kealey