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May 2, 2022 Newswires
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RIVERSOURCE LIFE INSURANCE CO – 10-Q – MANAGEMENT'S NARRATIVE ANALYSIS

Edgar Glimpses

Overview


RiverSource Life Insurance Company ("RiverSource Life") and its subsidiaries are
referred to collectively in this Form 10-Q as the "Company". The following
discussion and management's narrative analysis of the financial condition and
results of operations should be read in conjunction with the "Forward-Looking
Statements" that follow, the Consolidated Financial Statements and Notes
presented in Item 1 and its Annual Report on Form 10-K for the year ended
December 31, 2021 filed with the Securities and Exchange Commission ("SEC") on
February 25, 2022 ("2021 10-K"), as well as any current reports on Form 8-K and
other publicly available information.

The Consolidated Financial Statements are prepared in accordance with U.S.
generally accepted accounting principles ("GAAP"). Management's narrative
analysis is presented pursuant to General Instructions H(2)(a) of Form 10-Q in
lieu of Management's Discussion and Analysis of Financial Condition and Results
of Operations.

See Note 1 to the Consolidated Financial Statements for additional information.


The coronavirus disease 2019 (''COVID-19'') pandemic has presented ongoing
significant economic and societal disruption and market unpredictability, which
has affected the Company's business and operating environment driven by what has
been a low interest rate environment and volatility and changes in the equity
markets and the potential associated implications to client behavior. COVID-19
continues its ongoing impact and has been occurring in multiple waves, so there
are still no reliable estimates of how long the implications from the pandemic
will last, the effects current and other new variants will ultimately have, how
many people are likely to be affected by it, or its impact on the overall
economy. There is still significant uncertainty around the extent to which the
COVID-19 pandemic will continue to impact the Company's business, results of
operations, and financial condition, which depends on current and future
developments, including the ultimate scope, duration and severity of the
pandemic, success of worldwide vaccination efforts, multiple mutations of
COVID-19 or similar diseases, the effectiveness of the Company's office
reopenings, the additional measures that may be taken by various governmental
authorities in response to the outbreak, the actions of third parties in
response to the pandemic, and the possible further impacts on the global
economy. Given the ongoing impact of the pandemic, financial results may not be
comparable to previous years and the results presented in this report may not
necessarily be indicative of future operating results. For further information
regarding the impact of the COVID-19 pandemic, and any potentially material
effects, see Part 1 - Item 1A "Risk Factors" in the Company's 2021 10-K.

The Company consolidates certain variable interest entities for which it
provides investment management services. These entities are defined as
consolidated investment entities ("CIEs"). While the consolidation of the CIEs
impacts the Company's balance sheet and income statement, the exposure to these
entities is unchanged and there is no impact to the underlying business results.
For further information on CIEs, see Note 4 to the Consolidated Financial
Statements. Changes in the fair value of assets and liabilities related to the
CIEs, primarily syndicated loans and debt, are reflected in net investment
income.

Critical Accounting Estimates


The accounting and reporting policies that the Company uses affect its
Consolidated Financial Statements. Certain of the Company's accounting and
reporting policies are critical to an understanding of the Company's financial
condition and results of operations. In some cases, the application of these
policies can be significantly affected by the estimates, judgments and
assumptions made by management during the preparation of the Consolidated
Financial Statements. These accounting policies are discussed in detail in
"Management's Narrative Analysis - Critical Accounting Estimates" in the
Company's 2021 10-K.

Recent Accounting Pronouncements


For information regarding recent accounting pronouncements and their expected
impact on the Company's future consolidated financial condition or results of
operations, see Note 2 to the Consolidated Financial Statements.

                                                                            

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                       RIVERSOURCE LIFE INSURANCE COMPANY

Consolidated Results of Operations for the Three Months Ended March 31, 2022 and
2021


The following table presents the Company's consolidated results of operations:
                                                         Three Months Ended March 31,
                                                            2022               2021                     Change
                                                                         (in millions)
Revenues
Premiums                                                $       73          $     78          $    (5)             (6) %
Net investment income                                          159               247              (88)            (36)
Policy and contract charges                                    564               547               17               3
Other revenues                                                 173               128               45              35
Net realized investment gains (losses)                          18                48              (30)            (63)
Total revenues                                                 987             1,048              (61)             (6)

Benefits and expenses
Benefits, claims, losses and settlement expenses               210               652             (442)            (68)
Interest credited to fixed accounts                            141               159              (18)            (11)
Amortization of deferred acquisition costs                      92                 2               90             NM
Interest and debt expense                                       19                21               (2)            (10)
Other insurance and operating expenses                         171               194              (23)            (12)
Total benefits and expenses                                    633             1,028             (395)            (38)
Pretax income                                                  354                20              334             NM
Income tax provision                                            39                 2               37             NM
Net income                                              $      315          $     18          $   297             NM
NM  Not Meaningful.


Overall

Net income increased $297 million for the three months ended March 31, 2022
compared to the prior year period. Pretax income increased $334 million, for the
three months ended March 31, 2022 compared to the prior year period.

The following impacts were significant drivers of the period-over-period change
in pretax income:


•The market impact on non-traditional long-duration products (including variable
and fixed deferred annuity contracts and universal life ("UL") insurance
contracts), net of hedges and the related deferred sales inducement costs
("DSIC") and deferred acquisition costs ("DAC") amortization, unearned revenue
amortization and the reinsurance accrual was a benefit of $134 million for the
three months ended March 31, 2022 compared to an expense of $396 million for the
prior year period.

•The impact on variable annuity and variable universal life products for the
difference between assumed and updated separate account investment performance
on DAC, DSIC, unearned revenue amortization, reinsurance accrual and additional
insurance benefit reserves ("mean reversion related impact") was an expense of
$59 million for the three months ended March 31, 2022 compared to a benefit of
$56 million for the prior year period.

•A $45 million unfavorable impact due to more normalized long term care ("LTC")
insurance claims in the current period compared to the benefit of COVID-19
related impacts in the year ago period.


•Net realized investment gains of $18 million for the three months ended March
31, 2022 compared to net realized investment gains of $48 million for the prior
year period.

Variable annuity account balances decreased 1% to $85.8 billion as of March 31,
2022 compared to the prior year period due to net outflows of $1.9 billion,
partially offset by market appreciation. Variable annuity sales decreased 27%
compared to the prior year period reflecting a decrease in sales of variable
annuities with living benefit guarantees. The risk profile of its inforce block
continues to improve, with account values with living benefit riders down to 60%
as of March 31, 2022 compared to 63% a year ago. This trend is expected to
continue and meaningfully shift the mix of business away from products with
living benefit guarantees over time.

The Company continues to optimize its risk profile and shift its business mix to
lower risk offerings. During the fourth quarter of 2021, the Company made the
decision to discontinue new sales of substantially all of its variable annuities
with living benefit guarantees at the end of 2021, with a full exit by mid-2022.
In addition, the Company has discontinued new sales of its universal life
insurance with secondary guarantees and its single-pay fixed universal life with
a long term care rider products at the end of 2021.

                                                                            

42

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                       RIVERSOURCE LIFE INSURANCE COMPANY
Fixed deferred annuity account balances declined 4% to $7.5 billion as of March
31, 2022 compared to the prior year period as policies continue to lapse and the
discontinuance of new sales of fixed deferred annuities and fixed index
annuities. During the third quarter of 2021, the Company closed on a transaction
to reinsure RiverSource Life's fixed deferred and immediate annuity policies.

Revenues

Net investment income decreased $88 million, or 36%, for the three months ended
March 31, 2022 compared to the prior year period reflecting lower average
invested assets due to the sale of investments to a reinsurer as a result of the
fixed deferred and immediate annuity reinsurance transaction, a decrease in
investment income on fixed maturities due to lower yields as a result of
continued low interest rates, and lower net investment income of consolidated
CIEs.

Policy and contract charges increased $17 million, or 3%, for the three months
ended March 31, 2022 compared to the prior year period primarily reflecting a
favorable change in unearned revenue amortization and the reinsurance accrual
offset to the market impact of IUL benefits.

Other revenues increased $45 million, or 35%, for the three months ended March
31, 2022 compared to the prior year period primarily reflecting the yield on
deposit receivables arising from reinsurance transactions.

Net realized investment gains were $18 million for the three months ended March
31, 2022 compared to net realized investment gains of $48 million for the prior
year period. The three months ended March 31, 2022 included net realized gains
of $17 million on Available-for-Sale securities. The three months ended March
31, 2021 included net realized gains of $49 million on Available-for-Sale
securities due to sales, calls and tenders.

Benefits and Expenses


Benefits, claims, losses and settlement expenses decreased $442 million, or 68%,
for the three months ended March 31, 2022 compared to the prior year period
primarily reflecting the following items:
•A $207 million decrease in expense primarily reflecting the impact of
year-over-year changes in the unhedged nonperformance credit spread risk
adjustment on variable annuity guaranteed benefits. The unfavorable impact of
the nonperformance credit spread was $18 million for the three months ended
March 31, 2022 compared to an unfavorable impact of $225 million for the prior
year period. As the undiscounted embedded derivative liability on which the
nonperformance credit spread is applied increases (decreases), the impact of the
nonperformance credit spread on benefits expenses is favorable (unfavorable).
Additionally, as the estimate of the nonperformance credit spread over the LIBOR
swap curve tightens or widens, the embedded derivative liability will increase
or decrease.

•A $339 million decrease in expense from other market impacts on variable
annuity guaranteed benefits, net of hedges in place to offset those risks and
the related DSIC amortization. This decrease was the result of a favorable $1.3
billion change in the market impact on derivatives hedging the variable annuity
guaranteed benefits, partially offset by an unfavorable $950 million change in
the market impact on variable annuity guaranteed living benefits reserves. The
main market drivers contributing to these changes are summarized below:

•Equity market impact on the variable annuity guaranteed living benefits
liability net of the impact on the corresponding hedge assets resulted in a
benefit for the three months ended March 31, 2022 compared to an expense for the
prior year period.

•Interest rate impact on the variable annuity guaranteed living benefits
liability net of the impact on the corresponding hedge assets resulted in a
higher expense for the three months ended March 31, 2022 compared to the prior
year period.


•Volatility impact on the variable annuity guaranteed living benefits liability
net of the impact on the corresponding hedge assets resulted in a lower expense
for the three months ended March 31, 2022 compared to the prior year period.

•Other unhedged items, including the difference between the assumed and actual
underlying separate account investment performance, fixed income credit
exposures, transaction costs and various behavioral items, were a net expense
for the three months ended March 31, 2022 compared to a net benefit for the
prior year period.

•The mean reversion related impact was an expense of $34 million for the three
months ended March 31, 2022 compared to a benefit of $34 million for the prior
year period.

•A $41 million increase in expense on LTC insurance as claims returned to more
normalized levels compared to the prior year period which benefited from
COVID-19 related impacts.

Interest credited to fixed accounts decreased $18 million, or 11%, for the three
months ended March 31, 2022 compared to the prior year period primarily
reflecting the following items:


•A $29 million decrease in expense from the unhedged nonperformance credit
spread risk adjustment on IUL benefits. The favorable impact of the
nonperformance credit spread was $28 million for the three months ended March
31, 2022 compared to an unfavorable impact of $1 million for the prior year
period.

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                       RIVERSOURCE LIFE INSURANCE COMPANY
•A $14 million increase in expense from other market impacts on IUL benefits,
net of hedges, which was an expense of $12 million for the three months ended
March 31, 2022 compared to a benefit of $2 million for the prior year period.
The increase in expense was primarily due to an increase in the IUL embedded
derivative in the current period, which reflected higher option costs due to a
higher new money rate.

Amortization of DAC increased $90 million, for the three months ended March 31,
2022
compared to the prior year period primarily reflecting the following items:


•The DAC offset to the market impact on non-traditional long-duration products
was an expense of $11 million for the three months ended March 31, 2022 compared
to a benefit of $46 million for the prior year period.

•The mean reversion related impact was an expense of $25 million for the three
months ended March 31, 2022 compared to a benefit of $22 million for the prior
year period.

•A decrease in amortization reflecting lower than expected client exit rates.


Other insurance and operating expenses decreased $23 million, or 12%, for the
three months ended March 31, 2022 compared to the prior year period primarily
reflecting lower expenses from the consolidation of CIEs.

Income Taxes


The Company's effective tax rate was 11.1% for the three months ended March 31,
2022 compared to 9.1% for the prior year period. The increase in the effective
tax rate for the three months ended March 31, 2022 compared to March 31, 2021 is
primarily the result of higher pretax income and a decrease in low income
housing tax credits, partially offset by an increase in foreign tax credits in
the current period compared to the prior period. See Note 15 to the Consolidated
Financial Statements for additional discussion on income taxes.

Market Risk


The Company's primary market risk exposures are interest rate, equity price and
credit risk. Equity price and interest rate fluctuations can have a significant
impact on the Company's results of operations, primarily due to the effects on
asset-based fees and expenses, the "spread" income generated on its fixed
insurance, fixed portion of its variable annuities and variable insurance
contracts, and the fixed deferred annuities, the value of DAC and DSIC assets,
the value of liabilities for guaranteed benefits associated with its variable
annuities and the value of derivatives held to hedge these benefits.

The Company's earnings from fixed insurance, the fixed portion of variable
annuities and variable insurance contracts, and fixed deferred annuities are
based upon the spread between rates earned on assets held and the rates at which
interest is credited to accounts. The Company primarily invests in fixed rate
securities to fund the rate credited to clients. The Company guarantees an
interest rate to the holders of these products. Investment assets and client
liabilities generally differ as it relates to basis, repricing or maturity
characteristics. Rates credited to clients' accounts generally reset at shorter
intervals than the yield on the underlying investments. Therefore, in an
increasing interest rate environment, higher interest rates may be reflected in
crediting rates to clients sooner than in rates earned on invested assets, which
could result in a reduced spread between the two rates, reduced earned income
and a negative impact on pretax income. However, the current low interest rate
environment is resulting in interest rates below the level of some of the
Company's liability guaranteed minimum interest rates ("GMIRs"). Hence, a modest
rise in interest rates would not necessarily result in changes to all the
liability credited rates while projected asset purchases would capture the full
increase in interest rates. This dynamic would result in widening spreads under
a modestly rising rate scenario given the current relationship between the
current level of interest rates and the underlying GMIRs on the business.

As a result of the current interest rate environment, the Company's reinvestment
yields are generally lower than the current portfolio yield. The Company expects
its portfolio income yields to continue to decline in future periods should
interest rates remain comparatively low. The carrying value and weighted average
yield of total non-structured fixed maturity securities and commercial mortgage
loans in the Company's investment portfolio that may generate proceeds to
reinvest through March 31, 2024 due to prepayment, maturity or call activity at
the option of the issuer, excluding securities with a make-whole provision, were
$1.0 billion and 3.9%, respectively, as of March 31, 2022. In addition,
residential mortgage-backed securities, which could be subject to prepayment
risk if the low interest rate environment continues, totaled $2.4 billion and
had a weighted average yield of 2.1% as of March 31, 2022. While these amounts
represent investments that could be subject to reinvestment risk, it is also
possible that these investments will be used to fund liabilities or may not be
prepaid and will remain invested at their current yields. In addition to the
interest rate environment, the mix of benefit payments versus product sales as
well as the timing and volumes associated with such mix may impact the Company's
investment yield. Furthermore, reinvestment activities and the associated
investment yield may also be impacted by corporate strategies implemented at
management's discretion. The average yield for investment purchases during the
three months ended March 31, 2022 was approximately 2.9%.

                                                                            

44

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                       RIVERSOURCE LIFE INSURANCE COMPANY
The reinvestment of proceeds from maturities, calls and prepayments at rates
below the current portfolio yield, which may be below the level of some
liability GMIRs, will have a negative impact to future operating results. To
mitigate the unfavorable impact that the low interest rate environment has on
the Company's spread income, it assesses reinvestment risk in its investment
portfolio and monitors this risk in accordance with its asset/liability
management framework. In addition, the Company may reduce the crediting rates on
its fixed products when warranted, subject to guaranteed minimums.

In addition to the fixed rate exposures noted above, the Company also has the
following variable annuity guarantee benefits: guaranteed minimum withdrawal
benefits ("GMWB"), guaranteed minimum accumulation benefits ("GMAB"), guaranteed
minimum death benefits ("GMDB") and guaranteed minimum income benefits ("GMIB").
Each of these benefits guarantees payouts to the annuity holder under certain
specific conditions regardless of the performance of the underlying invested
assets.

The variable annuity guarantees continue to be managed by utilizing a hedging
program which attempts to match the sensitivity of the assets with the
sensitivity of the liabilities. This approach works with the premise that
matched sensitivities will produce a highly effective hedging result. The
Company's comprehensive hedging program focuses mainly on first order
sensitivities of assets and liabilities: Equity Market Level (Delta), Interest
Rate Level (Rho) and Volatility (Vega). Additionally, various second order
sensitivities are managed. The Company uses various options, swaptions, swaps
and futures to manage risk exposures. The exposures are measured and monitored
daily and adjustments to the hedge portfolio are made as necessary.

The Company has a macro hedge program to provide protection against the
statutory tail scenario risk arising from variable annuity reserves on its
statutory surplus and to cover some of the residual risks not covered by other
hedging activities. The Company assesses this residual risk under a range of
scenarios in creating and executing the macro hedge program. As a means of
economically hedging these risks, the Company may use a combination of futures,
options, swaps and swaptions. Certain of the macro hedge derivatives used
contain settlement provisions linked to both equity returns and interest rates;
the remaining are interest rate contracts or equity contracts. The macro hedge
program could result in additional earnings volatility as changes in the value
of the macro hedge derivatives, which are designed to reduce statutory capital
volatility, may not be closely aligned to changes in the variable annuity
guarantee embedded derivatives.

To evaluate interest rate and equity price risk, the Company performs
sensitivity testing which measures the impact on pretax income from the sources
listed below for a 12-month period following a hypothetical 100 basis point
increase in interest rates or a hypothetical 10% decline in equity prices. The
interest rate risk test assumes a sudden 100 basis point parallel shift in the
yield curve, with rates then staying at those levels for the next 12 months. The
equity price risk test assumes a sudden 10% drop in equity prices, with equity
prices then staying at those levels for the next 12 months. In estimating the
values of variable annuity riders, indexed annuities, IUL insurance and the
associated hedge assets, the Company assumed no change in implied market
volatility despite the 10% drop in equity prices.

The following tables present the Company's estimate of the impact on pretax
income from the above defined hypothetical market movements as of March 31,
2022
:

                                                                                         Equity Price Exposure to Pretax Income
                  Equity Price Decline 10%                                   Before Hedge Impact                   Hedge Impact           Net Impact
                                                                                                      (in millions)
Asset-based fees and expenses                                      $           (66)                              $           -          $       (66)
DAC and DSIC amortization (1) (2)                                              (26)                                          -                  (26)
Variable annuities:
GMDB and GMIB (2)                                                              (12)                                          -                  (12)
GMWB (2)                                                                      (499)                                        556                   57
GMAB                                                                           (27)                                         28                    1
Structured variable annuities                                                  397                                        (365)                  32
DAC and DSIC amortization (3)                                                                          N/A                    N/A               (12)
Total variable annuities                                                      (141)                                        219                   66
Macro hedge program (4)                                                          -                                         119                  119

IUL insurance                                                                   66                                         (71)                  (5)
Total                                                              $          (167)                              $         267          $        88


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                       RIVERSOURCE LIFE INSURANCE COMPANY

                                                                                                  Interest Rate Exposure to Pretax Income
                Interest Rate Increase 100 Basis Points                               Before Hedge Impact                 Hedge Impact           Net Impact
                                                                                                               (in millions)
Asset-based fees and expenses                                                 $          (14)                           $           -          $        (14)
Variable annuities:

GMWB                                                                                   1,031                                   (1,263)                 (232)
GMAB                                                                                       9                                      (12)                   (3)
Structured variable annuities                                                            (20)                                     117                   

97

DAC and DSIC amortization (3)                                                                                 N/A                    N/A                 21
Total variable annuities                                                               1,020                                   (1,158)                 (117)
Macro hedge program (4)                                                                    -                                       (1)                   (1)

Fixed annuities, fixed insurance and fixed portion of variable
annuities and variable insurance products

              53                                        -                    53
IUL insurance                                                                             19                                        2                    21
Total                                                                         $        1,078                            $      (1,157)         $        (58)


N/A Not Applicable.

(1) Market impact on DAC and DSIC amortization resulting from lower projected
profits.


(2) In estimating the impact to pretax income on DAC and DSIC amortization and
additional insurance benefit reserves, the assumed equity asset growth rates
reflect what management would follow in its mean reversion guidelines.

(3) Market impact on DAC and DSIC amortization related to variable annuity
riders is modeled net of hedge impact.

(4) The market impact of the macro hedge program is modeled net of any related
impact to DAC and DSIC amortization.


The above results compare to an estimated positive net impact to pretax income
of $98 million related to a 10% equity price decline and an estimated negative
net impact to pretax income of $170 million related to a 100 basis point
increase in interest rates as of December 31, 2021. The change in interest rate
exposure as of March 31, 2022 compared to December 31, 2021 was driven by
variable annuity riders, specifically GMWB, primarily due to changes in market
rates.

Net impacts shown in the above table from GMWB riders result largely from
differences between the liability valuation basis and the hedging basis.
Liabilities are valued using fair value accounting principles, with risk margins
incorporated in contractholder behavior assumptions and with discount rates
increased to reflect a current market estimate of the Company's risk of
nonperformance specific to these liabilities. The Company's hedging is based on
its determination of economic risk, which excludes certain items in the
liability valuation including the nonperformance spread risk.

Actual results will differ materially from those illustrated above as they are
based on a number of estimates and assumptions. These include assuming that
implied market volatility does not change when equity prices fall by 10% and
that the 100 basis point increase in interest rates is a parallel shift of the
yield curve. Furthermore, the Company has not tried to anticipate changes in
client preferences for different types of assets or other changes in client
behavior, nor has the Company tried to anticipate all strategic actions
management might take to increase revenues or reduce expenses in these
scenarios.

The selection of a 100 basis point interest rate increase as well as a 10%
equity price decline should not be construed as a prediction of future market
events. Impacts of larger or smaller changes in interest rates or equity prices
may not be proportional to those shown for a 100 basis point increase in
interest rates or a 10% decline in equity prices.

Fair Value Measurements


The Company reports certain assets and liabilities at fair value; specifically,
separate account assets, derivatives, embedded derivatives, most investments and
cash equivalents. Fair value assumes the exchange of assets or liabilities
occurs in orderly transactions and is not the result of a forced liquidation or
distressed sale. The Company includes actual market prices, or observable
inputs, in its fair value measurements to the extent available. Broker quotes
are obtained when quotes from pricing services are not available. The Company
validates prices obtained from third parties through a variety of means such as:
price variance analysis, subsequent sales testing, stale price review, price
comparison across pricing vendors and due diligence reviews of vendors. See Note
11 to the Consolidated Financial Statements for additional information on the
Company's fair value measurements.

Fair Value of Liabilities and Nonperformance Risk


Companies are required to measure the fair value of liabilities at the price
that would be received to transfer the liability to a market participant (an
exit price). Since there is not a market for the Company's obligations of its
variable annuity riders, fixed deferred indexed annuities, structured variable
annuities, and IUL insurance, the Company considers the assumptions participants
in a hypothetical market would make to reflect an exit price. As a result, the
Company adjusts the valuation of variable annuity riders, fixed deferred indexed
annuities, structured variable annuities, and IUL insurance by updating certain
contractholder assumptions,

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                       RIVERSOURCE LIFE INSURANCE COMPANY
adding explicit margins to provide for risk, and adjusting the rates used to
discount expected cash flows to reflect a current market estimate of the
Company's nonperformance risk. The nonperformance risk adjustment is based on
observable market data adjusted to estimate the risk of the Company not
fulfilling these liabilities. Consistent with general market conditions, this
estimate resulted in a spread over the LIBOR swap curve as of March 31, 2022. As
the Company's estimate of this spread widens or tightens, the liability will
decrease or increase. If this nonperformance credit spread moves to a zero
spread over the LIBOR swap curve, the reduction to future net income would be
approximately $420 million, net of DAC, DSIC, unearned revenue amortization, the
reinsurance accrual and income taxes (calculated at the statutory tax rate of
21%), based on March 31, 2022 credit spreads.

Liquidity and Capital Resources

Liquidity Strategy


The liquidity requirements of the Company are generally met by funds provided by
investment income, maturities and periodic repayments of investments, premiums
and proceeds from sales of investments, fixed annuity and fixed insurance
deposits as well as capital contributions from its parent, Ameriprise Financial
Inc. ("Ameriprise Financial"). Other liquidity sources the Company has
established are short-term borrowings and available lines of credit with
Ameriprise Financial aggregating $854 million.

The Company enters into short-term borrowings, which may include repurchase
agreements and Federal Home Loan Bank ("FHLB") advances to reduce reinvestment
risk. Short-term borrowings allow the Company to receive cash to reinvest in
longer-duration assets, while maintaining the flexibility to pay back the
short-term debt with cash flows generated by the fixed income portfolio.
RiverSource Life Insurance Company is a member of the FHLB of Des Moines, which
provides RiverSource Life Insurance Company access to collateralized borrowings.
As of both March 31, 2022 and December 31, 2021, the Company had estimated
maximum borrowing capacity of $4.0 billion under the FHLB facility, of which
$200 million was outstanding as of both March 31, 2022 and December 31, 2021,
and is collateralized with commercial mortgage backed securities.

There have been no material changes to the Company's contractual obligations
disclosed in the Company's 2021 10-K.

See Note 10 to the Consolidated Financial Statements for further information
about the Company's long-term debt.


The primary uses of funds are policy benefits, commissions, other
product-related acquisition and sales inducement costs, operating expenses,
policy loans, dividends to Ameriprise Financial and investment purchases. The
Company routinely reviews its sources and uses of funds in order to meet its
ongoing obligations. The Company believes these cash flows will be sufficient to
fund its short-term and long-term operating liquidity needs and dividends to
Ameriprise Financial.

In 2009, the Company established an agreement to protect its exposure to
Genworth Life Insurance Company ("GLIC") for its reinsured long term care
("LTC"). In 2016, substantial enhancements to this reinsurance protection
agreement were finalized. The terms of these confidential provisions within the
agreement have been shared, in the normal course of regular reviews, with the
Company's domiciliary regulator and rating agencies. GLIC is domiciled in
Delaware, so in the event GLIC were subjected to rehabilitation or insolvency
proceedings, such proceedings would be located in (and governed by) Delaware
laws. Delaware courts have a long tradition of respecting commercial and
reinsurance affairs as well as contracts among sophisticated parties. Similar
credit protections to what the Company has with GLIC have been tested and
respected in Delaware and elsewhere in the United States, and as a result the
Company believes its credit protections would be respected even in the unlikely
event that GLIC becomes subject to rehabilitation or insolvency proceedings in
Delaware. Accordingly, while no credit protections are perfect, the Company
believes the correct way to think about the risks represented by its
counterparty credit exposure to GLIC is not the full amount of the gross
liability that GLIC reinsures, but a much smaller net exposure to GLIC (if any
that might exist after taking into account the Company's credit protections).
Thus, management believes that this agreement and offsetting non LTC legacy
arrangements with Genworth will enable the Company to recover on all net
exposure in all material respects in the event of a rehabilitation or insolvency
of GLIC.

Capital Activity

Cash dividends or distributions paid and received by RiverSource Life Insurance
Company were as follows:
                                        Three Months Ended March 31,
                                              2022                     2021
                                               (in millions)
Paid to Ameriprise Financial   $           300                        $ 250

For dividends or distributions from the life insurance companies, notifications
to state insurance regulators were made in advance of payments in excess of
statutorily defined thresholds.

47

--------------------------------------------------------------------------------

                       RIVERSOURCE LIFE INSURANCE COMPANY

Regulatory Capital


RiverSource Life Insurance Company and RiverSource Life of NY are subject to
regulatory capital requirements. Actual capital, determined on a statutory
basis, and regulatory capital requirements for each of the life insurance
entities were as follows:
                                                                                                              Regulatory Capital
                                                                       Actual Capital (1)                      Requirements (2)
                                                                                      December 31,               December 31,
                                                              March 31, 2022              2021                       2021
                                                                                          (in millions)
RiverSource Life Insurance Company                           $    3,131             $       3,419          $                  502
RiverSource Life Insurance Co. of NY                                273                       310                              42


(1) Actual capital, as defined by the National Association of Insurance
Commissioners
for purposes of meeting regulatory capital requirements, includes
statutory capital and surplus, plus certain statutory valuation reserves.


(2) Regulatory capital requirement is the company action level and is based on
the statutory risk-based capital filing. The regulatory capital requirement is
only required to be calculated annually.

Forward-Looking Statements

This report contains forward-looking statements that reflect the Company's
plans, estimates and beliefs. The Company's actual results could differ
materially from those described in these forward-looking statements. Examples of
such forward-looking statements include:


•statements of the Company's plans, intentions, expectations, objectives, or
goals, including those related to the introduction, cessation, terms or pricing
of new or existing products and services and the consolidated tax rate;

•statements of the Company's position, future performance and ability to pursue
business strategy relative to the spread and impact of the COVID-19 pandemic and
the related market, economic, client, governmental and healthcare system
response;

•statements about the expected trend in the shift to lower-risk products,
including the exit from variable annuities with living benefit riders and the
discontinuance of new sales of universal life insurance with secondary
guarantees;


•other statements about future economic performance, the performance of equity
markets and interest rate variations and the economic performance of the United
States and of global markets; and

•statements of assumptions underlying such statements.


The words "believe," "expect," "anticipate," "optimistic," "intend," "plan,"
"aim," "will," "may," "should," "could," "would," "likely," "forecast," "on
track," "project," "continue," "able to remain," "resume," "deliver," "develop,"
"evolve," "drive," "enable," "flexibility," "scenario," "case" and similar
expressions are intended to identify forward-looking statements but are not the
exclusive means of identifying such statements. Forward-looking statements are
subject to risks and uncertainties which could cause actual results to differ
materially from such statements.

Such factors include, but are not limited to:

•the impacts on the Company's business of the COVID-19 pandemic and the related
economic, client, governmental and healthcare system responses;

•market fluctuations and general economic and political factors, including
volatility in the U.S. and global market conditions, client behavior and
volatility in the markets for the Company's products;

•changes in interest rates and periods of low interest rates;

•adverse capital and credit market conditions or any downgrade in the Company's
credit ratings;

•effects of competition and the Company's larger competitors' economies of
scale;

•declines in the Company's investment management performance;

•the Company's and its affiliates' ability to compete in attracting and
retaining talent, including AFS attracting and retaining financial advisors;

•impairment, negative performance or default by financial institutions or other
counterparties;

•poor performance of the Company's variable products;

•changes in valuation of securities and investments included in the Company's
assets;

•effects of the elimination of LIBOR on, and value of, securities and other
assets and liabilities tied to LIBOR;

•the determination of the amount of allowances taken on loans and investments;

•the illiquidity of the Company's investments;

•failures by other insurers that lead to higher assessments the Company owes to
state insurance guaranty funds;

•failures or defaults by counterparties to the Company's reinsurance
arrangements;

•inadequate reserves for future policy benefits and claims or for future
redemptions and maturities;

•deviations from the Company's assumptions regarding morbidity, mortality and
persistency affecting the Company's profitability;

•changes to the Company's or its affiliates' reputation arising from employee or
agent misconduct or otherwise;

•direct or indirect effects of or responses to climate change;

48

--------------------------------------------------------------------------------

                       RIVERSOURCE LIFE INSURANCE COMPANY

•interruptions or other failures in the Company's operating systems and
networks, including errors or failures caused by third-party service providers,
interference or third-party attacks;

•interruptions or other errors in the Company's telecommunications or data
processing systems;

•identification and mitigation of risk exposure in market environments, new
products, vendors and other types of risk;

•occurrence of natural or man-made disasters and catastrophes;

•legal and regulatory actions brought against the Company;

•changes to laws and regulations that govern operation of the Company's
business;

•changes in corporate tax laws and regulations and interpretations and
determinations of tax laws impacting the Company's products;

•protection of the Company's intellectual property and claims the Company
infringes the intellectual property of others; and

•changes in and the adoption of new accounting standards.


The Company cautions the reader that the foregoing list of factors is not
exhaustive. There may also be other risks that the Company is unable to predict
at this time that may cause actual results to differ materially from those in
forward-looking statements. Readers are cautioned not to place undue reliance on
these forward-looking statements, which speak only as of the date on which they
are made. The Company undertakes no obligation to update publicly or revise any
forward-looking statements. The foregoing list of factors should be read in
conjunction with the "Risk Factors" discussion included in Part I, Item 1A of
the Company's 2021 10-K.

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