Jnlny Separate Account I, et al. – ‘485BPOS’ on 12/21/06

On:  Thursday, 12/21/06, at 5:01pm ET   ·   Effective:  12/22/06   ·   Accession #:  927730-6-292   ·   File #s:  333-70384, 811-08401

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Post-Effective Amendment
Filing Table of Contents

Document/Exhibit                   Description                      Pages   Size 

 1: 485BPOS     Post-Effective Amendment                              63±   284K 
 2: EX-99       Miscellaneous Exhibit                                  8     34K 
 3: EX-99       Miscellaneous Exhibit                                  8±    44K 
 4: EX-99       Miscellaneous Exhibit                                 55±   249K 
 5: EX-99       Miscellaneous Exhibit                                  1      8K 
 6: EX-99       Miscellaneous Exhibit                                  1      6K 

485BPOS   —   Post-Effective Amendment
Document Table of Contents

485BPOS
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           As filed with Securities and Exchange Commission on December 21, 2006
                                                  Commission File Nos. 333-70384
                                                                       811-08401

 UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
--------------

FORM N-4
--------------

REGISTRATION STATEMENT UNDER THE SECURITIES ACT OF 1933                         

Pre-Effective Amendment No.                [ ]                                  

Post-Effective Amendment No. 24            |X|                                  

and/or                    

REGISTRATION STATEMENT UNDER THE INVESTMENT COMPANY ACT OF 1940                 

Amendment No. 88                           |X|                                  

--------------
JNLNY Separate Account I
(Exact Name of Registrant)
--------------

 Jackson National Life Insurance Company of New York
 (Name of Depositor)

 2900 Westchester Avenue, Purchase, New York 10577
(Address of Depositor's Principal Executive Offices)

 Depositor's Telephone Number, including Area Code: (517) 381-5500

 Thomas J. Meyer, Esq.
Senior Vice President, Secretary and General Counsel
 Jackson National Life Insurance Company
 1 Corporate Way
 Lansing, MI 48951
 (Name and Address of Agent for Service)

Copy to:

Anthony L. Dowling, Esq.
 Jackson National Life Insurance Company
 1 Corporate Way
 Lansing, MI 48951

It is proposed that this filing will become effective:                          

___  immediately upon filing pursuant to paragraph (b)                          
_X_  on December 22, 2006, pursuant to paragraph (b)                            
___  60 days after filing pursuant to paragraph (a)(1)                          
___  on [date] pursuant to paragraph (a)(1) of Rule 485                         

If appropriate, check the following box:                                        

___  This post-effective amendment designates a new effective date for a        
previously filed post-effective amendment.                            

Title of Securities Being  Registered:  the variable portion of Flexible Premium
Fixed and Variable Deferred Annuity contracts.                                  

EXPLANATORY NOTE: This amendment  supplements the prospectus.  Parts B and C are
also amended as indicated.  The amendment does not otherwise  delete,  amend, or
supersede any other  information in the  registration  statement,  as previously
amended,  including  exhibits and  undertakings.  Accordingly,  Parts A and B of
Post-Effective  Amendment  No.  23, as filed on April 27,  2006  (Accession  No.
0000927730-05-000111),  as thereafter  supplemented,  are hereby incorporated by
reference.                                                                      

485BPOS
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SUPPLEMENT DATED DECEMBER 22, 2006
 TO THE PROSPECTUS DATED MAY 1, 2006 FOR

 PERSPECTIVE II(R)

ISSUED BY JACKSON NATIONAL LIFE INSURANCE COMPANY OF NEW YORK(R)
THROUGH JNLNY SEPARATE ACCOUNT I

THIS SUPPLEMENT UPDATES THE PROSPECTUS FOR CONTRACTS SOLD ON OR AFTER JANUARY   
16, 2007. PLEASE READ AND KEEP IT TOGETHER WITH YOUR COPY OF THE PROSPECTUS FOR 
FUTURE REFERENCE.                                                               

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

*    Nine new Investment  Divisions of the Separate Account are available,  each
of which invests in the following funds - all Class A shares:         

JNL SERIES TRUST                                                      

JNL/CREDIT SUISSE GLOBAL NATURAL RESOURCES FUND                       
JNL/CREDIT SUISSE LONG/SHORT FUND                                     
JNL/FRANKLIN TEMPLETON FOUNDING STRATEGY FUND                         
JNL/FRANKLIN TEMPLETON GLOBAL GROWTH FUND                             
JNL/FRANKLIN TEMPLETON MUTUAL SHARES FUND                             
JNL/PIMCO REAL RETURN FUND                                            
JNL/S&P DISCIPLINED MODERATE FUND                                     
JNL/S&P DISCIPLINED MODERATE GROWTH FUND                              
JNL/S&P DISCIPLINED GROWTH FUND                                       

*    Also, please note the following fund name changes:                         

JNL SERIES TRUST                                                                
    JNL/PPM AMERICA VALUE EQUITY FUND (FORMERLY, JNL/PUTNAM VALUE EQUITY FUND)
  JNL/WESTERN ASSET HIGH YIELD BOND FUND (FORMERLY, JNL/WESTERN HIGH YIELD
BOND FUND)                                                        
JNL/WESTERN ASSET STRATEGIC BOND FUND (FORMERLY, JNL/WESTERN STRATEGIC
BOND FUND)                                                        
JNL/WESTERN ASSET U.S. GOVERNMENT & QUALITY BOND FUND (FORMERLY,      
JNL/WESTERN U.S. GOVERNMENT & QUALITY BOND FUND)                  

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

*    Under FEES AND  EXPENSES  TABLES,  please  replace  the "Total  Annual Fund
Operating Expenses" table with the following.                         

--------------------------------------------                    
Minimum: 0.60%                  

Maximum: 1.89%                  

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

*    Under FEES AND EXPENSES TABLES, with the fee table entitled "Fund Operating
     Expenses,"  please note the expenses  charged by the  following  nine newly
     available  funds. In addition,  please note the revised expenses charged by
     JNL/PPM America Value Equity Fund,  formerly  JNL/Putnam Value Equity Fund.
     Also,  the below  footnotes  replace  the  corresponding  footnotes  in the
prospectus.                                                           

                                                        [Enlarge/Download Table]

                                                                                                                           

                   FUND OPERATING EXPENSES                                                                                 
  (AS AN ANNUAL PERCENTAGE OF THE FUND'S AVERAGE DAILY NET                                                                 
                           ASSETS)                                                                                         
                                                                                                                ANNUAL     
                                                                 MANAGEMENT AND     SERVICE        OTHER       OPERATING   
                          FUND NAME                               ADMIN FEE A     (12B-1) FEE    EXPENSES B     EXPENSES   
--------------------------------------------------------------- ---------------- -------------- ------------- -------------
---------------------------------------------------------------- --------------- -------------- ------------- -------------
JNL/Credit Suisse Global Natural Resources                           0.85%           0.20%         0.01%         1.06%     
---------------------------------------------------------------- --------------- -------------- ------------- -------------
---------------------------------------------------------------- --------------- -------------- ------------- -------------
JNL/Credit Suisse Long/Short                                         1.00%           0.20%          0.50%D       1.70%     
---------------------------------------------------------------- --------------- -------------- ------------- -------------
---------------------------------------------------------------- --------------- -------------- ------------- -------------
JNL/Franklin Templeton Founding Strategy E                           0.05%           0.00%         0.01%         0.06%     
---------------------------------------------------------------- --------------- -------------- ------------- -------------
---------------------------------------------------------------- --------------- -------------- ------------- -------------
JNL/Franklin Templeton Global Growth                                 0.90%           0.20%         0.01%         1.11%     
---------------------------------------------------------------- --------------- -------------- ------------- -------------
---------------------------------------------------------------- --------------- -------------- ------------- -------------
JNL/Franklin Templeton Mutual Shares                                 0.85%           0.20%         0.01%         1.06%     
---------------------------------------------------------------- --------------- -------------- ------------- -------------
---------------------------------------------------------------- --------------- -------------- ------------- -------------
JNL/PIMCO Real Return                                                0.60%           0.20%         0.01%         0.81%     
---------------------------------------------------------------- --------------- -------------- ------------- -------------
---------------------------------------------------------------- --------------- -------------- ------------- -------------
JNL/PPM America Value Equity                                         0.65%           0.20%         0.01%         0.86%     
---------------------------------------------------------------- --------------- -------------- ------------- -------------
---------------------------------------------------------------- --------------- -------------- ------------- -------------
JNL/S&P Disciplined Moderate C                                       0.18%           0.00%         0.01%         0.19%     
---------------------------------------------------------------- --------------- -------------- ------------- -------------
---------------------------------------------------------------- --------------- -------------- ------------- -------------
JNL/S&P Disciplined Moderate Growth C                                0.18%           0.00%         0.01%         0.19%     
---------------------------------------------------------------- --------------- -------------- ------------- -------------
---------------------------------------------------------------- --------------- -------------- ------------- -------------
JNL/S&P Disciplined Growth C                                         0.18%           0.00%         0.01%         0.19%     
---------------------------------------------------------------- --------------- -------------- ------------- -------------

A    Certain   Funds  pay  Jackson   National   Asset   Management,   LLC,   the
     Administrator,  an administrative  fee for certain services provided to the
     Fund by the  Administrator.  The JNL/Credit Suisse Global Natural Resources
     Fund, the JNL/Credit  Suisse  Long/Short Fund, the  JNL/Franklin  Templeton
     Global  Growth  Fund,  the  JNL/JPMorgan  International  Equity  Fund,  the
     JNL/JPMorgan  International  Value Fund,  the JNL/Lazard  Emerging  Markets
     Fund, the JNL/Oppenheimer  Global Growth Fund, the JNL/Select Global Growth
     Fund  and  all  of the  JNL/Mellon  Capital  Management  Funds  except  the
     JNL/Mellon  Capital  Management S&P 500 Index Fund, the JNL/Mellon  Capital
     Management  S&P 400 MidCap Index Fund, the  JNL/Mellon  Capital  Management
     Small Cap Index Fund, the JNL/Mellon  Capital  Management  Bond Index Fund,
     and the JNL/Mellon  Capital Management Global 15 Fund an administrative fee
     of  0.15%;  the  JNL/Mellon  Capital  Management  Global  15  Fund  pays an
     administrative  fee of 0.20%; the JNL/Franklin  Templeton Founding Strategy
     Fund and the 12 JNL/S&P Funds pay an  administrative  fee of 0.05%; and the
     other  Funds  pay  an  administrative  fee of  0.10%.  The  Management  and
     Administrative  Fee and the Annual Operating Expenses columns in this table
reflect the inclusion of any applicable administrative fee.           

B    Other expenses include registration fees, licensing costs, a portion of the
     Chief Compliance Officer costs, directors and officers insurance,  the fees
     and  expenses of the  disinterested  Trustees/Managers  and of  independent
legal counsel to the disinterested Trustees/Managers.                 

C    UNDERLYING FUND EXPENSES. The expenses shown above are the annual operating
     expenses for the JNL/S&P  Funds.  Because the JNL/S&P Funds invest in other
     Funds of the JNL Series Trust and JNL Variable  Fund LLC, the JNL/S&P Funds
     will  indirectly  bear its pro  rata  share  of fees  and  expenses  of the
underlying Funds in addition to the expenses shown.                   

     The total annual  operating  expenses for each JNL/S&P Fund (including both
     the  annual  operating  expenses  for the  JNL/S&P  Funds  and  the  annual
     operating  expenses  for the  underlying  Funds)  could range from 0.76% to
     1.89% (this range  reflects an  investment in the Funds with the lowest and
     highest Annual Operating  Expenses).  The table below shows estimated total
     annual  operating  expenses for each of the JNL/S&P  Funds based on the pro
     rata share of expenses  that the JNL/S&P  Funds would bear if they invested
     in a  hypothetical  mix of  underlying  Funds.  The  Adviser  believes  the
     expenses  shown  below to be a likely  approximation  of the  expenses  the
     JNL/S&P Funds will incur based on the actual mix of underlying  Funds.  The
     expenses  shown below  include both the annual  operating  expenses for the
     JNL/S&P Fund and the annual  operating  expenses for the underlying  Funds.
     The actual expenses of each JNL/S&P Fund will be based on the actual mix of
     underlying Funds in which it invests. The actual expenses may be greater or
less than those shown.                                                

     JNL/S&P Managed Conservative Fund                             1.04%
     JNL/S&P Managed Moderate Fund                                 1.08%
     JNL/S&P Managed Moderate Growth Fund                          1.09%
     JNL/S&P Managed Growth Fund                                   1.13%
     JNL/S&P Managed Aggressive Growth Fund                        1.16%
     JNL/S&P Retirement Income Fund                                1.05%
     JNL/S&P Retirement 2015 Fund                                  1.13%
     JNL/S&P Retirement 2020 Fund                                  1.15%
     JNL/S&P Retirement 2025 Fund                                  1.16%
     JNL/S&P Disciplined Moderate Fund                             0.89%
     JNL/S&P Disciplined Moderate Growth Fund                      0.86%
     JNL/S&P Disciplined Growth Fund                               0.85%

D    Amount includes the estimated costs  associated with the Fund's short sales
     on equity  securities.  The percentage shown  represents  estimates for the
     Fund's initial year of operations and assumes that the Fund maintains short
     equity  positions  of  approximately  20% of its  net  assets.  When a cash
     dividend  is  declared  on a  security  for  which  the Fund  holds a short
     position,  the Fund incurs the  obligation  to pay an amount  equal to that
     dividend to the lender of the shorted  security.  Dividend expense on short
     sales is  estimated to be 0.37% of the 0.50%.  In  addition,  the Fund will
     incur fees in  connection  with the  borrowing  of  securities  in order to
     effect the short sale  transactions,  which is estimated to be 0.12% of the
     0.50%.  The Fund's  actual  dividend  expenses  paid and stock loan fees on
     securities  sold  short  may be  significantly  higher  or  lower  than the
     estimates  above due to,  among  other  factors,  the actual  extent of the
     Fund's  short  positions,  the actual  dividends  paid with  respect to the
     securities the Fund sells short,  and the actual timing of the Fund's short
sale transactions, each of which is expected to vary over time.       

E    UNDERLYING FUND EXPENSES. The expenses shown above are the annual operating
     expenses for the JNL/Franklin Templeton Founding Strategy Fund. Because the
     JNL/Franklin  Templeton  Founding Strategy Fund invests in the JNL/Franklin
     Templeton Income Fund, the  JNL/Franklin  Templeton Global Growth Fund, and
     the JNL/Franklin  Templeton Mutual Shares Fund, the JNL/Franklin  Templeton
     Founding  Strategy Fund will indirectly bear its pro rata share of fees and
     expenses of the  Underlying  Funds in addition to the expenses  shown.  The
     JNL/Franklin   Templeton  Founding  Strategy  Fund  expense  including  the
expenses for the Underlying Funds is 1.15%.                           

*    Under FEES AND EXPENSES TABLES,  please replace the  corresponding  example
with the following.                                                   

        EXAMPLE. The example below is intended to help you compare the cost of
        investing in the Contract with the cost of investing in other variable
   annuity contracts. These costs include Contract Owner transaction
         expenses, Contract fees, Separate Account annual expenses and Fund fees
and expenses.                                                 

       (The Annual Contract Maintenance Charge is determined by dividing the
        total amount of such charges collected during the calendar year by the
    total market value of the Investment Divisions and Fixed Account.)

     The example assumes that you invest $10,000 in the Contract for the
       time periods indicated. Neither transfer fees nor premium tax charges
  are reflected in the example. The example also assumes that your
investment has a 5% annual return on assets each year.        

       The following example includes maximum Fund fees and expenses and the
      cost if you select the optional 2% Contract Enhancement, the Highest
       Anniversary Death Benefit, the Five-year Withdrawal Schedule, the 20%
   Additional Free Withdrawal, and the Guaranteed Minimum Withdrawal
         Benefit (using the maximum possible charge). Although your actual costs
      may be higher or lower, based on these assumptions, your costs would
be:                                                           

  If you surrender your Contract at the end of the applicable time
period:                                                       

  1 year              3 years           5 years           10 years
$1,496              $2,336            $3,291            $5,918

If you annuitize at the end of the applicable time period:    

  1 year *            3 years          5 years            10 years
$1,496              $2,336           $3,291             $5,918

        *    Withdrawal  charges apply to income payments occurring within one
year of the Contract's Issue Date.                  

If you do NOT surrender your Contract:                        

  1 YEAR             3 YEARS            5 YEARS           10 YEARS
$646               $1,911             $3,141            $5,918

     THE EXAMPLE DOES NOT REPRESENT PAST OR FUTURE EXPENSES. YOUR ACTUAL
COSTS MAY BE HIGHER OR LOWER.                                 

--------------------------------------------------------------------------------
*    Under THE ANNUITY  CONTRACT,  please  replace the last  paragraph  with the
following.                                                            

        The Contract is a flexible premium fixed and variable deferred annuity
     and may be issued as either an individual or a group contract. This
prospectus provides a description of the material rights and  
        obligations under the Contract. Your Contract and any endorsements are
the formal contractual agreement between you and the Company. 

--------------------------------------------------------------------------------
*    Under  INVESTMENT  DIVISIONS,  with the JNL  SERIES  TRUST,  please add the
following information about the newly available funds.                

--------------------------------------------------------------------------------
JNL/CREDIT SUISSE GLOBAL NATURAL RESOURCES FUND                                 
     Jackson National Asset Management, LLC (and Credit Suisse Asset Management,
LLC and Credit Suisse Asset Management Limited (sub-sub-adviser))     

         Seeks long-term growth of capital by investing a minimum of 95% (of the
majority of its assets) of its assets in worldwide companies. 

--------------------------------------------------------------------------------
JNL/CREDIT SUISSE LONG/SHORT FUND                                               
     Jackson National Asset Management, LLC (and Credit Suisse Asset Management,
LLC)                                                                  

      Seeks total return by investing through a quantitative active equity
management strategy that allows the portfolio to underweight  
  unattractive stocks beyond benchmark weights, resulting in short
positions on certain stocks.                                  

--------------------------------------------------------------------------------
JNL/FRANKLIN TEMPLETON FOUNDING STRATEGY FUND                                   
Jackson National Asset Management, LLC                                

    Seeks capital appreciation by investing in a combination of mutual
        funds (Underlying Funds) on a fixed percentage basis. These Underlying
        Funds, in turn invest primarily in U.S. and foreign equity securities,
    and, to a lesser extent, fixed-income and money market securities.

--------------------------------------------------------------------------------
JNL/FRANKLIN TEMPLETON GLOBAL GROWTH FUND                                       
Jackson National Asset Management, LLC (and Templeton Global Advisors 
Limited)                                                              

     Seeks long-term capital growth by investing primarily in the equity
  securities of companies located anywhere in the world, including
emerging markets (under normal market conditions).            

--------------------------------------------------------------------------------
JNL/FRANKLIN TEMPLETON MUTUAL SHARES FUND                                       
    Jackson National Asset Management, LLC (and Franklin Mutual Advisers, LLC)

       Seeks capital appreciation, which may occasionally be short-term, and
       secondarily, income by investing in equity securities of companies in
        any nation, pursuant to manager discretion. The Fund invests primarily
        (up to 80%) in mid- and large-cap companies with market capitalization
        greater than $1.5 billion at the time of investment, but it may invest
     a significant portion of its assets in small-cap companies as well.

--------------------------------------------------------------------------------
JNL/PIMCO REAL RETURN FUND                                                      
   Jackson National Asset Management, LLC (and Pacific Investment Management
Company LLC)                                                          

         Seeks maximum real return, consistent with preservation of real capital
and prudent investment management by investing under normal   
         circumstances at least 80% of its assets (net assets plus the amount of
       any borrowings for investment purposes) in inflation-indexed bonds of
       varying maturities issued by the U.S. and non-U.S. governments, their
agencies or government-sponsored enterprises and corporations.

--------------------------------------------------------------------------------
JNL/S&P DISCIPLINED MODERATE FUND                                               
  Jackson National Asset Management, LLC (and Standard & Poor's Investment
Advisory Services LLC)                                                

       Seeks capital growth, and secondarily, current income by investing in
  Class A shares of a diversified group of other Funds (Underlying
     Funds), which are part of the JNL Series Trust and the JNL Variable
Fund LLC. The Fund seeks to achieve capital growth through its
 investments in Underlying Funds that invest primarily in equity
  securities. The Fund seeks to achieve current income through its
       investments in Underlying Funds that invest primarily in fixed-income
securities.                                                   

--------------------------------------------------------------------------------
JNL/S&P DISCIPLINED MODERATE GROWTH FUND                                        
  Jackson National Asset Management, LLC (and Standard & Poor's Investment
Advisory Services LLC)                                                

       Seeks capital growth, and secondarily, current income by investing in
  Class A shares of a diversified group of other Funds (Underlying
     Funds), which are part of the JNL Series Trust and the JNL Variable
Fund LLC. The Fund seeks to achieve capital growth through its
 investments in Underlying Funds that invest primarily in equity
  securities. The Fund seeks to achieve current income through its
       investments in Underlying Funds that invest primarily in fixed-income
securities.                                                   

--------------------------------------------------------------------------------
JNL/S&P DISCIPLINED GROWTH FUND                                                 
  Jackson National Asset Management, LLC (and Standard & Poor's Investment
Advisory Services LLC)                                                

         Seeks capital growth, and current income by investing in Class A shares
     of a diversified group of other Funds (Underlying Funds), which are
      part of the JNL Series Trust and the JNL Variable Fund LLC. The Fund
       seeks to achieve capital growth through its investments in Underlying
     Funds that invest primarily in equity securities. The Fund seeks to
         achieve current income through its investments in Underlying Funds that
invest primarily in fixed-income securities.                  

*    Under INVESTMENT  DIVISIONS,  with the JNL SERIES TRUST, please replace the
     fund objective  paragraph for the former  JNL/Putnam Value Equity Fund with
the following.                                                        

--------------------------------------------------------------------------------
JNL/PPM AMERICA VALUE EQUITY FUND                                               
Jackson National Asset Management, LLC (and PPM America, Inc.)        

        Seeks long-term capital growth by investing primarily in a diversified
  portfolio of equity securities of domestic, large-capitalization
         companies at least 80% of its assets (net assets plus the amount of any
    borrowings for investment purposes) will be invested, under normal
circumstances, in equity securities.                          

--------------------------------------------------------------------------------
*    Under CONTRACT CHARGES,  in the subsection  entitled  "Withdrawal  Charge,"
please replace the second bulleted paragraph with the following.      

o     EARNINGS (excess of your Contract Value allocated to the  
          Investment Divisions and the Fixed Account over your remaining
premium in these Options)                           

*    Under  CONTRACT  CHARGES,  in the  subsection  entitled  "Joint 5% For Life
     Guaranteed  Minimum  Withdrawal Benefit With Annual Step-Up Charge," please
replace the first paragraph with the following.                       

     JOINT 5% FOR LIFE GUARANTEED MINIMUM WITHDRAWAL BENEFIT WITH ANNUAL
    STEP-UP CHARGE. The charge for this GMWB is expressed as an annual
      percentage of the GWB and depends on the youngest Covered Life's age
     when the endorsement is added to the Contract. For more information
       about the GWB and for information on who is a Covered Life under this
    form of GMWB, please see the "Joint 5% For Life Guaranteed Minimum
       Withdrawal Benefit With Annual Step-Up" subsection of this Prospectus
        under the heading ACCESS TO YOUR MONEY. The charge varies by age group
       (see table below), and both Covered Lives must be within the eligible
age range.                                                    

*    Under  CONTRACT  CHARGES,  in the  subsection  entitled  "Joint 5% For Life
     Guaranteed  Minimum  Withdrawal  Benefit With Bonus And  Five-Year  Step-Up
Charge," please replace the first paragraph with the following.       

        JOINT 5% FOR LIFE GUARANTEED MINIMUM WITHDRAWAL BENEFIT WITH BONUS AND
       FIVE-YEAR STEP-UP CHARGE. The charge for this GMWB is expressed as an
         annual percentage of the GWB and depends on the youngest Covered Life's
         age when the endorsement is added to the Contract. For more information
       about the GWB and for information on who is a Covered Life under this
    form of GMWB, please see the "Joint 5% For Life Guaranteed Minimum
         Withdrawal Benefit With Bonus And Five-Year Step-Up" subsection of this
        Prospectus under the heading "ACCESS TO YOUR MONEY." The charge varies
       by age group (see table below), and both Covered Lives must be within
the eligible age range.                                       

*    The following  section  entitled  "Distribution  of Contracts,"  formerly a
     subsection under CONTRACT  CHARGES,  contains revised language and is now a
separate section.                                                     

 DISTRIBUTION OF CONTRACTS

  Jackson National Life Distributors LLC ("JNLD"), located at 7601
      Technology Way, Denver, Colorado 80237, serves as the distributor of
      the Contracts. JNLD is a wholly owned subsidiary of Jackson National
Life Insurance Company, Jackson National Life of NY's parent. 

      Commissions are paid to broker-dealers who sell the Contracts. While
         commissions may vary, they are not expected to exceed 8% of any premium
     payment. Where lower commissions are paid up front, we may also pay
      trail commissions. We may also pay commissions on the Income Date if
     the annuity option selected involves a life contingency or a payout
over a period of ten or more years.                           

    Under certain circumstances, JNLD out of its own resources may pay
  bonuses, overrides, and marketing allowances, in addition to the
  standard commissions. These cash payments, or reimbursements, to
       broker-dealers are in recognition of their marketing and distribution
        and/or administrative services support. They may not be offered to all
    broker-dealers, and the terms of any particular agreement may vary
      among broker-dealers depending on, among other things, the level and
  type of marketing and distribution support provided assets under
   management, and the volume and size of the sales of our insurance
      products. Such compensation is subject to applicable state insurance
law and regulation and the NASD rules of conduct.             

       The two primary forms of such compensation paid by JNLD are overrides
 and marketing support payments. Overrides are payments that are
designed as consideration for product placement, assets under 
       management and sales volume. Overrides are generally based on a fixed
     percentage of product sales and currently range from 10 to 50 basis
        points (0.10% to 0.50%). Marketing support payments may be in the form
   of cash and/or non-cash compensation and allow us to, among other
    things, participate in sales conferences and educational seminars.
Examples of such payments include, but are not limited to,    
  reimbursements for representative training meetings, prospecting
       seminars, and business development and educational enhancement items.
    Payments or reimbursements for meetings and seminars are generally
      based on the anticipated level of participation and/or accessibility
and the size of the audience.                                 

         Below is an alphabetical listing of the 19 broker-dealers that received
         the largest amounts of marketing and distribution and/or administrative
     support in 2005 from the Distributor in relation to the sale of our
insurance products:                                           

A. G. Edwards & Sons, Inc.                    
Centaurus Financial                           
Commonwealth Financial Group, Inc.            
Fifth Third Securities, Inc.                  
Hantz Financial Services, Inc.                
IFMG Securities, Inc.                         
Investment Centers of America, Inc.           
Inter Securities Inc.                         
Invest Financial Corp.                        
Linsco/Private Ledger Corp.                   
Mutual Service Corporation                    
National Planning Corporation                 
Prime Capital Services, Inc.                  
Raymond James & Associates, Inc.              
Securities America, Inc.                      
SII Investments, Inc.                         
Thrivent Financial for Lutherans              
Wachovia Securities, LLC                      
WM Financial Services                         

  Please see Appendix D for a complete list of broker-dealers that
      received amounts of marketing and distribution and/or administrative
     support in 2005 from the Distributor in relation to the sale of our
insurance products.                                           

        We may, under certain circumstances where permitted by applicable law,
     pay a bonus to a Contract purchaser to the extent the broker-dealer
        waives its commission. You can learn about the amount of any available
 bonus by calling the toll-free number on the cover page of this
         prospectus. Contract purchasers should inquire of the representative if
         such bonus is available to them and its compliance with applicable law.
If you elect the optional Three Year Withdrawal Charge Period 
  endorsement, if available, a lower commission may be paid to the
         registered representative who sells you your Contract than if you elect
         to purchase the product without that endorsement. We may use any of our
   corporate assets to cover the cost of distribution, including any
        profit from the Contract's mortality and expense risk charge and other
 charges. Besides Jackson National Life Distributors LLC, we are
affiliated with the following broker-dealers:                 

*      National Planning Corporation,         

*      SII Investments, Inc.,                 

               *      IFC Holdings, Inc. d/b/a Invest Financial Corporation,

 *      Investment Centers of America, Inc., and

*      Curian Clearing LLC                    

The Distributor also has the following relationships with the 
      sub-advisers and their affiliates. The Distributor receives payments
       from certain sub-advisers to assist in defraying the costs of certain
   promotional and marketing meetings in which they participate. The
  amounts paid depend on the nature of the meetings, the number of
       meetings attended, the costs expected to be incurred and the level of
the sub-adviser's participation. National Planning Corporation
       participates in the sales of shares of retail mutual funds advised by
   certain sub-advisers and other unaffiliated entities and receives
   selling and other compensation from them in connection with those
       activities, as described in the prospectus or statement of additional
     information for those funds. The fees range between 0.30% and 0.45%
  depending on these factors. In addition, the Distributor acts as
       distributor of variable annuity contracts and variable life insurance
        policies (the "Other Contracts") issued by Jackson National Life of NY
        and Jackson National Life Insurance Company, its parent. Raymond James
     Financial Services, a brokerage affiliate of the sub-adviser to the
JNL/Eagle Funds, participates in the sale of Contracts and is 
 compensated by JNLD for its activities at the standard rates of
       compensation. Unaffiliated broker-dealers are also compensated at the
standard rates of compensation. The compensation consists of  
      commissions, trail commissions and other compensation or promotional
     incentives as described above and in the prospectus or statement of
additional information for the Other Contracts.               

   All of the compensation described here, and other compensation or
      benefits provided by JNLNY or our affiliates, may be greater or less
      than the total compensation on similar or other products. The amount
    and/or structure of the compensation may influence your registered
      representative, broker-dealer or selling institution to present this
Contract over other investment alternatives. The variations in
        compensation, however, may also reflect differences in sales effort or
        ongoing customer services expected of the registered representative or
         the broker-dealer. You may ask your registered representative about any
variations and how he or she and his or her broker-dealer are 
compensated for selling the Contract.                         

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

*    Under ACCESS TO YOUR MONEY, in the subsection entitled  "Guaranteed Minimum
     Withdrawal Benefit Considerations," please replace the two bullets with the
following.                                                            

        o    If the Contract Value falls to zero,  benefit  payments under the
             endorsement  will continue  until the death of the last surviving
             Covered Life if the For Life  Guarantee is  effective.  (For more
             information  about the For Life Guarantee and for  information on
             who is a Covered  Life  under  this form of GMWB,  please see the
             "Joint 5% For Life  Guaranteed  Minimum  Withdrawal  Benefit With
             Annual  Step-Up"  or the  "Joint 5% For Life  Guaranteed  Minimum
             Withdrawal Benefit With Bonus And Five-Year Step-Up"  subsections
found later in this prospectus.)                    

        o    If an Owner dies before the automatic payment of benefits begins,
             the surviving  Covered Life may continue the Contract and the For
             Life Guarantee is not  automatically  terminated (as it is on the
For Life GMWBs without the Joint Option).           

*    Under  ACCESS TO YOUR  MONEY,  immediately  after the  subsection  entitled
     "Guaranteed  Minimum  Withdrawal  Benefit  Considerations,"  please add the
following subsection.                                                 

         GUARANTEED MINIMUM WITHDRAWAL BENEFIT IMPORTANT SPECIAL CONSIDERATIONS.
      Each of the GMWBs provides that the GMWB and all benefits thereunder
   will terminate on the Income Date, which is the date when annuity
         payments begin. The Income Date is either a date that you choose or the
     Latest Income Date. The Latest Income Date is the date on which the
       Owner attains age 90 under a Non-Qualified Contract, unless otherwise
  approved by the Company, or such earlier date as required by the
applicable qualified plan, law or regulation.                 

     Before (1) electing a GMWB, (2) electing to annuitize your Contract
      after having purchased a GMWB, or (3) when the Latest Income Date is
         approaching and you are thinking about electing or have elected a GMWB,
       you should consider whether the termination of all benefits under the
     GMWB and annuitizing produces the better financial results for you.
      Naturally, you should discuss with your JNL representative whether a
         GMWB is even suitable for you. Consultation with your financial and tax
advisor is also recommended.                                  

      These considerations are of greater significance if you are thinking
 about electing or have elected a GMWB For Life, as the For Life
     payments will cease when you annuitize voluntarily or on the Latest
      Income Date. To the extent that we can extend the Latest Income Date
         without adverse tax consequences to you, we will do so, as permitted by
   the applicable qualified plan, law, or regulation. After you have
       consulted your financial and tax advisors you will need to contact us
    to request an extension of the Latest Income Date. Please also see
     "Extension of Latest Income Date" beginning on page 111 for further
      information regarding possible adverse tax consequences of extending
the Latest Income Date.                                       

         In addition, with regard to required minimum distributions (RMDs) under
        an IRA only, it is important to consult your financial and tax advisor
     to determine whether the benefits of a particular GMWB will satisfy
        your RMD requirements or whether there are other IRA holdings that can
        satisfy the aggregate RMD requirements. With regard to other qualified
plans, you must determine what your qualified plan permits.   
      Distributions under qualified plans and Tax-Sheltered Annuities must
        begin by the later of the calendar year in which you attain age 70 1/2
       or the calendar year in which you retire. You do not necessarily have
to annuitize your Contract to meet the minimum distribution.  

*    Under ACCESS TO YOUR MONEY,  in the subsection  entitled "Joint 5% For Life
     Guaranteed  Minimum Withdrawal Benefit With Annual Step-Up," please replace
     the first several paragraphs of the subsection, up to but not including the
part entitled "ELECTION," with the following.                         

     JOINT 5% FOR LIFE GUARANTEED MINIMUM WITHDRAWAL BENEFIT WITH ANNUAL
       STEP-UP. The description of this GMWB is supplemented by the examples
   in Appendix C, particularly examples 5 and 6 for the Step-Ups and
example 9 for the For Life Guarantee.                         

         This GMWB is available currently for non-qualified Contracts with joint
       Owners. The joint Owners are required to be spouses (as defined under
       the Internal Revenue Code) and each joint Owner is considered to be a
"Covered Life."                                               

    The Owners cannot be subsequently changed and new Owners cannot be
         added. Upon death of either joint Owner, the surviving joint Owner will
        be treated as the primary Beneficiary and all other Beneficiaries will
         be treated as contingent Beneficiaries. The For Life Guarantee will not
         apply to these contingent Beneficiaries, as they are not Covered Lives.

         This GMWB is available on a limited basis under non-qualified Contracts
     for certain kinds of legal entities, such as (i) custodial accounts
      where the spouses are the joint annuitants and (ii) trusts where the
       spouses are the sole beneficial owners, and the For Life Guarantee is
based on the Annuitant's life who dies last.                  

BEGINNING JANUARY 16, 2007, this benefit is also available for
      tax-qualified Contracts. Tax-qualified Contracts cannot be issued to
         joint Owners and require the Owner and Annuitant to be the same person.
        Under a tax-qualified Contract, the election of this GMWB requires the
         Owner and primary Beneficiary to be spouses (as defined in the Internal
         Revenue Code). The Owner and only the primary spousal Beneficiary named
       at the election of this GMWB under a tax-qualified Contract will also
      each be considered a Covered Life, and these Covered Lives cannot be
subsequently changed.                                         

        For tax-qualified Contracts, the Owner and primary spousal Beneficiary
       cannot be changed while both are living. If the Owner dies first, the
primary spousal Beneficiary will become the Owner upon Spousal
  Continuation and he or she may name a Beneficiary; however, that
        Beneficiary is not considered a Covered Life. Likewise, if the primary
       spousal Beneficiary dies first, the Owner may name a new Beneficiary;
     however, that Beneficiary is also not considered a Covered Life and
consequently the For Life Guarantee will not apply to the new 
Beneficiary.                                                  

For both non-qualified and tax-qualified Contracts, this GMWB 
         guarantees partial withdrawals during the Contract's accumulation phase
(i.e., before the Income Date) for the LONGER of:             

               *    The lifetime of the last  surviving  Covered Life if the For
Life Guarantee is in effect;            

                     The For Life Guarantee becomes effective on the
                          Contract Anniversary on or immediately following the
                   youngest Covered Life's 65th birthday. If the
                           youngest Covered Life is 65 years old or older on the
                     endorsement's effective date, then the For Life
                           Guarantee is effective when this GMWB is added to the
Contract.                 

                     So long as the For Life Guarantee is in effect,
                           withdrawals are guaranteed even in the event Contract
Value is reduced to zero. 

OR                                                

               *    Until  all   withdrawals   under  the  Contract   equal  the
                    Guaranteed  Withdrawal  Balance  (GWB),  without  regard  to
Contract Value.                         

                           The GWB is the guaranteed amount available for future
periodic withdrawals.     

     BECAUSE OF THE FOR LIFE GUARANTEE, YOUR WITHDRAWALS COULD AMOUNT TO
     MORE THAN THE GWB. BUT PLEASE NOTE: THE GUARANTEES OF THIS GMWB ARE
      SUBJECT TO THE ENDORSEMENT'S TERMS, CONDITIONS, AND LIMITATIONS THAT
       ARE EXPLAINED IN THIS SUPPLEMENT, THE PROSPECTUS AND THE ENDORSEMENT.

      Please consult the representative who is helping, or who helped, you
        purchase your Contract to be sure that this GMWB ultimately suits your
needs.                                                        

      This GMWB is available to Covered Lives 45 to 80 years old (proof of
        age is required and both Covered Lives must be within the eligible age
     range). If the age of any Covered Life is incorrectly stated at the
time of election of the GMWB, on the date the misstatement is 
   discovered, the Contract Value will be adjusted by the difference
        between the charges actually paid and the charges that would have been
         paid assuming the correct age. Future GMWB charges will be based on the
  correct age. If the age at election of either Covered Life falls
         outside the allowable age range, the GMWB will be null and void and all
GMWB charges will be refunded.                                

  This GMWB may be added to a Contract on the Issue Date or on any
         Contract Anniversary and, if added PRIOR TO JANUARY 16, 2007, it cannot
    be canceled except by a spousal Beneficiary, who, upon the Owner's
     death, may elect to continue the Contract without the GMWB. If this
        GMWB is added ON JANUARY 16, 2007 OR LATER, then it cannot be canceled
      except by a spousal Beneficiary who is not a Covered Life, who, upon
         the Owner's death, may elect to continue the Contract without the GMWB.
     To continue joint GMWB coverage upon the death of the Owner (or the
         death of either joint Owner of a non-qualified Contract), provided that
        the other Covered Life is still living, the Contract must be continued
    by election of Spousal Continuation. Upon continuation, the spouse
becomes the Owner and obtains all rights as the Owner.        

      At least 30 calendar days' prior notice and proof of age is required
for Good Order to add this GMWB to a Contract on a Contract   
        Anniversary. THIS GMWB IS NOT AVAILABLE ON A CONTRACT THAT ALREADY HAS
      A GMWB (ONLY ONE GMWB PER CONTRACT) OR THE GUARANTEED MINIMUM INCOME
     BENEFIT (GMIB). Availability of this GMWB may be subject to further
limitation.                                                   

There is a limit on withdrawals each Contract Year to keep the
     guarantees of this GMWB in full effect, which is the maximum of the
    Guaranteed Annual Withdrawal Amount (GAWA) or the required minimum
         distribution. Withdrawals exceeding the limit do not invalidate the For
Life Guarantee, but cause the GWB and GAWA to be recalculated.

*    Under ACCESS TO YOUR MONEY,  in the subsection  entitled "Joint 5% For Life
     Guaranteed  Minimum  Withdrawal  Benefit With Annual  Step-Up," in the part
     entitled  "WITHDRAWALS,"  please  replace  the  last  sentence  of the last
paragraph with the following.                                         

       For more information about tax-qualified and non-qualified Contracts,
please see "TAXES" beginning on page 108.                     

*    Under ACCESS TO YOUR MONEY,  in the subsection  entitled "Joint 5% For Life
     Guaranteed  Minimum Withdrawal Benefit With Annual Step-Up," please replace
the part entitled "OWNER'S DEATH" with the following.                 

     OWNER'S DEATH. The Contract's death benefit is not affected by this
         GMWB SO LONG AS CONTRACT VALUE IS GREATER THAN ZERO and the Contract is
      still in the accumulation phase. Upon the death of the Owner (or the
    death of either joint Owner of a non-qualified Contract) while the
  Contract is still in force and before the Income Date, this GMWB
terminates without value unless continued by the spouse.      

*    Under ACCESS TO YOUR MONEY,  in the subsection  entitled "Joint 5% For Life
     Guaranteed  Minimum Withdrawal Benefit With Annual Step-Up," please replace
the part entitled "SPOUSAL CONTINUATION" with the following.          

    SPOUSAL CONTINUATION. In the event of the Owner's (or either joint
 Owner's) death, the surviving spousal beneficiary may elect to:

               *    Continue  the  Contract  WITH  this  GMWB - so  long  as the
                    Contract  Value is greater  than zero,  and the  Contract is
                    still in the  accumulation  phase.  (The  date  the  spousal
                    Beneficiary's  election to continue  the Contract is in Good
Order is called the Continuation Date.) 

                            *  If the surviving spouse is a Covered Life and the
                               For Life Guarantee is already in effect, then the
                               For Life Guarantee remains effective on and after
                              the Continuation Date. If the For Life Guarantee
                               is not already in effect and the surviving spouse
                               is a Covered Life, the For Life Guarantee becomes
                         effective on the Contract Anniversary on or
                         immediately following the youngest original
                               Covered Life's 65th birthday, and the above rules
                             for the For Life Guarantee apply. The effective
                               date of the For Life Guarantee will be set on the
                effective date of the endorsement.

                            If the surviving spouse is not a Covered Life,
                               the For Life Guarantee is null and void. However,
                           the surviving spouse will be entitled to make
                     withdrawals until the GWB is exhausted.

                        *  For a surviving spouse who is a Covered Life,
                       continuing the Contract with this GMWB is
                               necessary to be able to fully realize the benefit
                               of the For Life Guarantee. The For Life Guarantee
                             is not a separate guarantee and only applies if
                  the related GMWB has not terminated.

                     *  Step-Ups will continue automatically or as
                              permitted in accordance with the above rules for
Step-Ups.         

                           *  Contract Anniversaries will continue to be based
                    on the original Contract's Issue Date.

                  *  A new joint Owner may not be added in a
                          non-qualified Contract if a surviving spouse
     continues the Contract.

               *    Continue the Contract WITHOUT this GMWB (GMWB is terminated)
                    if the GMWB was added to the  Contract  PRIOR TO JANUARY 16,
          2007. Thereafter, no GMWB charge will be assessed.

               *    Continue the Contract WITHOUT this GMWB (GMWB is terminated)
                    if this GMWB was added to the  Contract  ON JANUARY 16, 2007
                    OR LATER and if the surviving  spouse is not a Covered Life.
                    Thereafter,   no  GMWB  charge  will  be  assessed.  If  the
                    surviving  spouse is a Covered Life, the Contract  cannot be
continued without this GMWB.            

               *    Add another GMWB to the Contract on any Contract Anniversary
                    after  the  Continuation   Date,   subject  to  the  spousal
                    Beneficiary's  eligibility,  and provided that this GMWB was
terminated on the Continuation Date.    

       For more information about spousal continuation of a Contract, please
  see "Special Spousal Continuation Option" beginning on page 107.

*    Under ACCESS TO YOUR MONEY,  in the subsection  entitled "Joint 5% For Life
     Guaranteed  Minimum Withdrawal Benefit With Annual Step-Up," please replace
the part entitled "TERMINATION" with the following.                   

     TERMINATION. This GMWB terminates subject to a prorated GMWB Charge
         assessed for the period since the last monthly statement charge and all
benefits cease on the earliest of:                            

*    The Income Date;                             

               *    The date of  complete  withdrawal  of  Contract  Value (full
surrender of the Contract);             

               *    The date of death of the  Owner  (or  either  joint  Owner),
                    UNLESS the  Beneficiary  who is the Owner's spouse elects to
                    continue the Contract with the GMWB (continuing the Contract
                    with this GMWB is necessary to be able to fully  realize the
                    benefit of the For Life Guarantee if the surviving spouse is
a Covered Life);                        

               *    The  Continuation  Date on a Contract in which this GMWB was
                    added PRIOR TO JANUARY  16, 2007 if the spousal  Beneficiary
         elects to continue the Contract without the GMWB;

               *    The  Continuation  Date on a Contract in which this GMWB was
                    added  ON  JANUARY  16,  2007  OR  LATER,   if  the  spousal
                    Beneficiary,  who is not a Covered Life,  elects to continue
the Contract without the GMWB; or       

               *    The date all obligations under this GMWB are satisfied after
the Contract Value is zero.             

      EFFECT OF GMWB ON TAX DEFERRAL. This GMWB may not be appropriate for
        Owners who have as a primary objective taking maximum advantage of the
   tax deferral that is available to them under an annuity contract.
        Please consult your tax and financial advisors before adding this GMWB
to a Contract.                                                

*    Under ACCESS TO YOUR MONEY,  in the subsection  entitled "Joint 5% For Life
     Guaranteed Minimum  Withdrawal  Benefit With Bonus And Five-Year  Step-Up,"
     please replace the first several  paragraphs of the  subsection,  up to but
not including the part entitled "Election," with the following.       

        JOINT 5% FOR LIFE GUARANTEED MINIMUM WITHDRAWAL BENEFIT WITH BONUS AND
        FIVE-YEAR STEP-UP. The description of this GMWB is supplemented by the
        examples in Appendix C, particularly examples 5 and 6 for the Step-Ups
and example 9 for the For Life Guarantee.                     

         This GMWB is available currently for non-qualified Contracts with joint
       Owners. The joint Owners are required to be spouses (as defined under
       the Internal Revenue Code) and each joint Owner is considered to be a
"Covered Life."                                               

    The Owners cannot be subsequently changed and new Owners cannot be
         added. Upon death of either joint Owner, the surviving joint Owner will
        be treated as the primary Beneficiary and all other Beneficiaries will
         be treated as contingent Beneficiaries. The For Life Guarantee will not
         apply to these contingent Beneficiaries, as they are not Covered Lives.

         This GMWB is available on a limited basis under non-qualified Contracts
     for certain kinds of legal entities, such as (i) custodial accounts
      where the spouses are the joint annuitants and (ii) trusts where the
       spouses are the sole beneficial owners, and the For Life Guarantee is
based on the Annuitant's life who dies last.                  

BEGINNING JANUARY 16, 2007, this benefit is also available for
      tax-qualified Contracts. Tax-qualified Contracts cannot be issued to
         joint Owners and require the Owner and Annuitant to be the same person.
        Under a tax-qualified Contract, the election of this GMWB requires the
         Owner and primary Beneficiary to be spouses (as defined in the Internal
         Revenue Code). The Owner and only the primary spousal Beneficiary named
       at the election of this GMWB under a tax-qualified Contract will also
      each be considered a Covered Life, and these Covered Lives cannot be
subsequently changed.                                         

        For tax-qualified Contracts, the Owner and primary spousal Beneficiary
       cannot be changed while both are living. If the Owner dies first, the
primary spousal Beneficiary will become the Owner upon Spousal
  Continuation and he or she may name a Beneficiary; however, that
        Beneficiary is not considered a Covered Life. Likewise, if the primary
       spousal Beneficiary dies first, the Owner may name a new Beneficiary;
  however, that Beneficiary is also not considered a Covered Life.

For both non-qualified and tax-qualified Contracts, this GMWB 
         guarantees partial withdrawals during the Contract's accumulation phase
(i.e., before the Income Date) for the LONGER of:             

               *    The lifetime of the last  surviving  Covered Life if the For
Life Guarantee is in effect;            

                     The For Life Guarantee becomes effective on the
                          Contract Anniversary on or immediately following the
                   youngest Covered Life's 65th birthday. If the
                           youngest Covered Life is 65 years old or older on the
                     endorsement's effective date, then the For Life
                           Guarantee is effective when this GMWB is added to the
Contract.                 

                     So long as the For Life Guarantee is in effect,
                           withdrawals are guaranteed even in the event Contract
Value is reduced to zero. 

OR                                                

               *    Until  all   withdrawals   under  the  Contract   equal  the
                    Guaranteed  Withdrawal  Balance  (GWB),  without  regard  to
Contract Value.                         

                           The GWB is the guaranteed amount available for future
periodic withdrawals.     

     BECAUSE OF THE FOR LIFE GUARANTEE, YOUR WITHDRAWALS COULD AMOUNT TO
     MORE THAN THE GWB. BUT PLEASE NOTE: THE GUARANTEES OF THIS GMWB ARE
      SUBJECT TO THE ENDORSEMENT'S TERMS, CONDITIONS, AND LIMITATIONS THAT
       ARE EXPLAINED IN THIS SUPPLEMENT, THE PROSPECTUS AND THE ENDORSEMENT.

      Please consult the representative who is helping, or who helped, you
        purchase your Contract to be sure that this GMWB ultimately suits your
needs.                                                        

      This GMWB is available to Covered Lives 45 to 80 years old (proof of
        age is required and both Covered Lives must be within the eligible age
     range). If the age of any Covered Life is incorrectly stated at the
time of election of the GMWB, on the date the misstatement is 
   discovered, the Contract Value will be adjusted by the difference
        between the charges actually paid and the charges that would have been
         paid assuming the correct age. Future GMWB charges will be based on the
  correct age. If the age at election of either Covered Life falls
         outside the allowable age range, the GMWB will be null and void and all
GMWB charges will be refunded.                                

  This GMWB may be added to a Contract on the Issue Date or on any
         Contract Anniversary and, if added PRIOR TO JANUARY 16, 2007, it cannot
    be canceled except by a Spousal Beneficiary, who, upon the Owner's
     death, may elect to continue the Contract without the GMWB. If this
        GMWB is added ON JANUARY 16, 2007 OR LATER, then it cannot be canceled
      except by a spousal Beneficiary who is not a Covered Life, who, upon
         the Owner's death, may elect to continue the Contract without the GMWB.
     To continue joint GMWB coverage upon the death of the Owner (or the
         death of either joint Owner of a non-qualified Contract), provided that
        the other Covered Life is still living, the Contract must be continued
    by election of Spousal Continuation. Upon continuation, the spouse
becomes the Owner and obtains all rights as the Owner.        

      At least 30 calendar days' prior notice and proof of age is required
for Good Order to add this GMWB to a Contract on a Contract   
        Anniversary. THIS GMWB IS NOT AVAILABLE ON A CONTRACT THAT ALREADY HAS
      A GMWB (ONLY ONE GMWB PER CONTRACT) OR THE GUARANTEED MINIMUM INCOME
     BENEFIT (GMIB). Availability of this GMWB may be subject to further
limitation.                                                   

There is a limit on withdrawals each Contract Year to keep the
     guarantees of this GMWB in full effect, which is the maximum of the
    Guaranteed Annual Withdrawal Amount (GAWA) or the required minimum
         distribution. Withdrawals exceeding the limit do not invalidate the For
Life Guarantee, but cause the GWB and GAWA to be recalculated.

*    Under ACCESS TO YOUR MONEY,  in the subsection  entitled "Joint 5% For Life
     Guaranteed Minimum Withdrawal Benefit With Bonus And Five-Year Step-Up," in
     the part entitled  "WITHDRAWALS,"  please  replace the last sentence of the
last paragraph with the following.                                    

       For more information about tax-qualified and non-qualified Contracts,
please see "TAXES" beginning on page 108.                     

*    Under ACCESS TO YOUR MONEY,  in the subsection  entitled "Joint 5% For Life
     Guaranteed Minimum  Withdrawal  Benefit With Bonus And Five-Year  Step-Up,"
please replace the part entitled "OWNER'S DEATH" with the following.  

     OWNER'S DEATH. The Contract's death benefit is not affected by this
         GMWB SO LONG AS CONTRACT VALUE IS GREATER THAN ZERO and the Contract is
       still in the accumulation phase. Upon the death of either joint Owner
  in a non-qualified Contract, or upon the death of the Owner of a
         tax-qualified Contract, while the Contract is still in force and before
        the Income Date, the GMWB terminates without value unless continued by
the spouse.                                                   

*    Under ACCESS TO YOUR MONEY,  in the subsection  entitled "Joint 5% For Life
     Guaranteed Minimum  Withdrawal  Benefit With Bonus And Five-Year  Step-Up,"
     please replace the part entitled "SPOUSAL CONTINUATION" with the following.

    SPOUSAL CONTINUATION. In the event of the Owner's (or either joint
 Owner's) death, the surviving spousal beneficiary may elect to:

               *    Continue  the  Contract  WITH  this  GMWB - so  long  as the
                    Contract  Value is greater  than zero,  and the  Contract is
                    still in the  accumulation  phase.  (The  date  the  spousal
                    Beneficiary's  election to continue  the Contract is in Good
Order is called the Continuation Date.) 

                            *  If the surviving spouse is a Covered Life and the
                               For Life Guarantee is already in effect, then the
                               For Life Guarantee remains effective on and after
                              the Continuation Date. If the For Life Guarantee
                               is not already in effect and the surviving spouse
                               is a Covered Life, the For Life Guarantee becomes
                         effective on the Contract Anniversary on or
                         immediately following the youngest original
                               Covered Life's 65th birthday, and the above rules
                             for the For Life Guarantee apply. The effective
                               date of the For Life Guarantee will be set on the
                effective date of the endorsement.

                            If the surviving spouse is not a Covered Life,
                               the For Life Guarantee is null and void. However,
                           the surviving spouse will be entitled to make
                     withdrawals until the GWB is exhausted.

                        *  For a surviving spouse who is a Covered Life,
                       continuing the Contract with this GMWB is
                               necessary to be able to fully realize the benefit
                               of the For Life Guarantee. The For Life Guarantee
                             is not a separate guarantee and only applies if
                  the related GMWB has not terminated.

                       *  The spouse may elect to step-up the Contract
                           Value on the first Contract Anniversary on or
                          immediately following the Continuation Date;
                          otherwise the above rules for Step-Up apply.

                          *  Bonuses will continue to apply according to the
      rules below for Bonuses.

                         *  Contract Anniversaries and Contract Years will
                             continue to be based on the original Contract's
Issue Date.       

                  *  A new joint Owner may not be added in a
                          non-qualified Contract if a surviving spouse
     continues the Contract.

               *    Continue the Contract WITHOUT this GMWB (GMWB is terminated)
                    if the GMWB was added to the  Contract  PRIOR TO JANUARY 16,
          2007. Thereafter, no GMWB charge will be assessed.

               *    Continue the Contract WITHOUT this GMWB (GMWB is terminated)
                    if this GMWB was added to the  Contract  ON JANUARY 16, 2007
                    OR LATER and if the surviving  spouse is not a Covered Life.
                    Thereafter,   no  GMWB  charge  will  be  assessed.  If  the
                    surviving  spouse is a Covered Life, the Contract  cannot be
continued without this GMWB.            

               *    Add another GMWB to the Contract on any Contract Anniversary
                    after  the  Continuation   Date,   subject  to  the  spousal
                    Beneficiary's  eligibility,  and provided that this GMWB was
terminated on the Continuation Date.    

       For more information about spousal continuation of a Contract, please
  see "Special Spousal Continuation Option" beginning on page 107.

*    Under ACCESS TO YOUR MONEY,  in the subsection  entitled "Joint 5% For Life
     Guaranteed Minimum  Withdrawal  Benefit With Bonus And Five-Year  Step-Up,"
please replace the part entitled "TERMINATION" with the following.    

     TERMINATION. This GMWB terminates subject to a prorated GMWB Charge
         assessed for the period since the last monthly statement charge and all
benefits cease on the earliest of:                            

*    The Income Date;                             

               *    The date of  complete  withdrawal  of  Contract  Value (full
surrender of the Contract);             

               *    The date of death of the  Owner  (or  either  joint  Owner),
                    UNLESS the  Beneficiary  who is the Owner's spouse elects to
                    continue the Contract with the GMWB (continuing the Contract
                    with this GMWB is necessary to be able to fully  realize the
                    benefit of the For Life Guarantee if the surviving spouse is
a Covered Life);                        

               *    The  Continuation  Date on a Contract in which this GMWB was
                    added PRIOR TO JANUARY  16, 2007 if the spousal  Beneficiary
         elects to continue the Contract without the GMWB;

               *    The  Continuation  Date on a Contract in which this GMWB was
                    added  ON  JANUARY  16,  2007  OR  LATER,   if  the  spousal
                    Beneficiary,  who is not a Covered Life,  elects to continue
the Contract without the GMWB; or       

               *    The date all obligations under this GMWB are satisfied after
the Contract Value is zero.             

      EFFECT OF GMWB ON TAX DEFERRAL. This GMWB may not be appropriate for
        Owners who have as a primary objective taking maximum advantage of the
   tax deferral that is available to them under an annuity contract.
        Please consult your tax and financial advisors before adding this GMWB
to a Contract.                                                

--------------------------------------------------------------------------------
*    Under  INCOME  PAYMENTS  (THE  INCOME  PHASE),  please  replace  the  third
paragraph with the following.                                         

     You can change the Income Date or income option at least seven days
         before the Income Date, but changes to the Income Date may only be to a
        later date. You must give us written notice at least seven days before
    the scheduled Income Date. Income payments must begin by your 90th
     birthday under a non-qualified Contract, or by such earlier date as
      required by the applicable qualified plan, law or regulation, unless
   otherwise approved by the Company. Under a traditional Individual
      Retirement Annuity, required minimum distributions must begin in the
    calendar year in which you attain age 70 1/2 (or such other age as
         required by law). Distributions under qualified plans and Tax-Sheltered
     Annuities must begin by the later of the calendar year in which you
        attain age 70 1/2 or the calendar year in which you retire. You do not
 necessarily have to annuitize your Contract to meet the minimum
distribution requirements for Individual Retirement Annuities,
       qualified plans, and Tax-Sheltered Annuities. Distributions from Roth
IRAs are not required prior to your death.                    

*    Under  INCOME  PAYMENTS  (THE INCOME  PHASE),  in the  subsection  entitled
     "Variable Income Payments,"  please add the following  paragraph before the
last paragraph.                                                       

         If the actual net investment rate experienced by an Investment Division
         exceeds the assumed net investment rate, variable annuity payments will
      increase over time. Conversely, if the actual net investment rate is
      less than the assumed net investment rate, variable annuity payments
       will decrease over time. If the actual net investment rate equals the
        assumed net investment rate, the variable annuity payments will remain
constant.                                                     

--------------------------------------------------------------------------------
* Under DEATH BENEFIT, please replace the subsection regarding calculations for 
the optional death benefit with the following.                                  

   HIGHEST ANNIVERSARY VALUE DEATH BENEFIT, changes your basic death
benefit to the greatest of:                                   

               (a)  your  Contract  Value as of the end of the  business  day on
                    which  we  receive  all  required  documentation  from  your
Beneficiary; or                         

        (b)  total Net Premiums since your Contract was issued; or

               (c)  your  greatest  Contract  Value on any Contract  Anniversary
                    prior  to  your  81st   birthday,   MINUS  any   withdrawals
                    (including   any   applicable    withdrawal    charges   and
                    adjustments),   the  Annual  Contract  Maintenance  Charges,
                    transfer  charges,  any  applicable  charges  due  under any
                    optional  endorsement and taxes  subsequent to that Contract
                    Anniversary,  PLUS any premiums paid (net of any  applicable
                    premium taxes) subsequent to that Contract Anniversary.  FOR
                    CONTRACTS  ISSUED  ON OR  AFTER  JANUARY  16,  2007,  ANNUAL
                    CONTRACT   MAINTENANCE   CHARGES,   TRANSFER  CHARGES,   ANY
                    APPLICABLE  CHARGES DUE UNDER ANY OPTIONAL  ENDORSEMENT  AND
                    TAXES  SUBSEQUENT TO THAT CONTRACT  ANNIVERSARY  WILL NOT BE
   DEDUCTED FROM YOUR GREATEST CONTRACT VALUE.

--------------------------------------------------------------------------------
*    Under TAXES, in the subsection  entitled "Extension of Latest Income Date,"
please replace the first sentence with the following.                 

      If you do not annuitize your non-qualified Contract on or before the
     latest Income Date, it is possible that the IRS could challenge the
  status of your Contract as an annuity Contract for tax purposes.

*    Under TAXES, in the subsection entitled "Owner Control," please replace the
second paragraph with the following.                                  

      The Contract will differ from the contracts described in the Revenue
       Ruling, in two respects. The first difference is that the contract in
 the Revenue Ruling provided only 12 investment options with the
     insurance company having the ability to add an additional 8 options
    whereas a Contract offers 76 Investment Divisions and at least one
         Fixed Account option, although a Contract owner can select no more than
         18 fixed and variable options at any one time. The second difference is
        that the owner of a contract in the Revenue Ruling could only make one
transfer per 30-day period without a fee whereas during the   
         accumulation phase, a Contract owner will be permitted to make up to 15
transfers in any one year without a charge.                   

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

*    Under APPENDIX C, please replace the entire appendix with the following.   

GMWB PROSPECTUS EXAMPLES

Unless otherwise specified, the following examples assume you elected a 5% GMWB 
when you purchased your Contract, no other optional benefits were elected, your 
initial premium payment was $100,000, your GAWA is greater than your RMD at the 
time a withdrawal is requested, and all partial withdrawals requested include   
any applicable charges. The examples also assume that the GMWB and any For Life 
guarantee have not been terminated as described in the Access to Your Money     
section of this prospectus. If you elected a GMWB other than a 5% GMWB, the     
examples will still apply, given that you replace the 5% in each of the GAWA    
calculations with the appropriate percentage.                                   

EXAMPLE 1: AT ELECTION, YOUR GWB AND GAWA ARE DETERMINED.                       

o    Example 1a: If the GMWB is elected at issue:                     

          o    Your  initial  GWB is  $100,000,  which is your  initial  Premium
payment.                                          

          o    Your  GAWA  is  $5,000,   which  is  5%  of  your   initial   GWB
($100,000*0.05 = $5,000).                         

     o    Example 1b: If the GMWB is elected after issue when the Contract Value
is $105,000:                                                

          o    Your initial GWB is $105,000, which is your Contract Value on the
effective date of the endorsement.                

          o    Your  GAWA  is  $5,250,   which  is  5%  of  your   initial   GWB
($105,000*0.05 = $5,250).                         

     o    Example 1c: If the GMWB is elected after issue when the Contract Value
          is $110,000 and your Contract  includes a Contract  Enhancement with a
     total Recapture Charge of $5,000 at the time the GMWB is elected:

          o    Your  initial  GWB is  $105,000,  which  is your  Contract  Value
               ($110,000)  less the Recapture  Charge  ($5,000) on the effective
date of the endorsement.                          

          o    Your  GAWA  is  $5,250,   which  is  5%  of  your   initial   GWB
($105,000*0.05 = $5,250).                         

o    Notes:                                                           

     o    If your  endorsement  includes a Guaranteed  Withdrawal  Balance Bonus
          provision,  your  bonus  base is set equal to your GWB and the time of
election.                                                   

EXAMPLE  2:  UPON  PAYMENT  OF A  SUBSEQUENT  PREMIUM,  YOUR  GWB AND  GAWA  ARE
RE-DETERMINED. YOUR GWB IS SUBJECT TO A MAXIMUM OF $5,000,000.                  

     o    Example 2a: If you make an additional  Premium  payment of $50,000 and
your GWB is $100,000 at the time of payment:                

          o    Your  new  GWB is  $150,000,  which  is  your  GWB  prior  to the
               additional   Premium  payment  ($100,000)  plus  your  additional
Premium payment ($50,000).                        

          o    Your GAWA is $7,500,  which is your GAWA prior to the  additional
               Premium  payment  ($5,000)  plus  5% of your  additional  Premium
payment ($50,000*0.05 = $2,500).                  

     o    Example 2b: If you make an additional  Premium payment of $100,000 and
          your  GWB is  $4,950,000  and  your  GAWA is  $247,500  at the time of
payment:                                                    

          o    Your new GWB is $5,000,000,  which is the maximum, since your GWB
               prior to the additional  Premium payment  ($4,950,000)  plus your
               additional  Premium  payment  ($100,000)  exceeds  the maximum of
$5,000,000.                                       

          o    Your GAWA is $250,000, which is your GAWA prior to the additional
               Premium  payment  ($247,500)  plus  5% of the  allowable  $50,000
             increase in your GWB (($5,000,000 - $4,950,000)*0.05 = $2,500).

o    Notes:                                                           

          o    If your  endorsement  includes a  Guaranteed  Withdrawal  Balance
               Bonus  provision,  your bonus base is  increased  by the  Premium
payment, subject to a maximum of $5,000,000.      

EXAMPLE 3: UPON WITHDRAWAL OF THE GUARANTEED AMOUNT (WHICH IS YOUR GAWA FOR     
ENDORSEMENTS FOR NON-QUALIFIED AND QUALIFIED CONTRACTS THAT DO NOT PERMIT       
WITHDRAWALS IN EXCESS OF THE GAWA OR WHICH IS THE GREATER OF YOUR GAWA OR YOUR  
RMD FOR THOSE GMWBS RELATED TO QUALIFIED CONTRACTS THAT PERMIT WITHDRAWALS IN   
EXCESS OF THE GAWA TO EQUAL YOUR RMD), YOUR GWB AND GAWA ARE RE-DETERMINED.     

     o    Example 3a: If you withdraw an amount equal to your GAWA ($5,000) when
your GWB is $100,000:                                       

          o    Your  new  GWB  is  $95,000,  which  is  your  GWB  prior  to the
               withdrawal ($100,000) less the amount of the withdrawal ($5,000).

          o    Your GAWA for the next  year  remains  $5,000,  since you did not
withdraw an amount that exceeds your GAWA.        

          o    If you continued to take annual  withdrawals  equal to your GAWA,
               it would take an additional 19 years,  prior to the Latest Income
               Date, to deplete your GWB ($95,000 / $5,000 per year = 19 years),
               provided that there are no further  adjustments  made to your GWB
               or your GAWA  (besides  the annual  reduction  of your GWB by the
               amount of the  withdrawal).  However,  if you have  elected a For
               Life GMWB and the For Life  Guarantee  is in effect,  withdrawals
               equal to your GAWA could  continue  for the rest of your life (or
               in the case of Joint  Owners,  until the first death of the Joint
               Owners or until the death of the last  surviving  Covered Life if
               your  endorsement  is a For Life GMWB with  Joint  Option),  even
beyond 19 years, prior to the Latest Income Date. 

     o    Example  3b: If you  withdraw  an amount  equal to your RMD  ($7,500),
          which is greater than your GAWA ($5,000) when your GWB is $100,000 and
your RMD provision is in effect for your endorsement:       

          o    Your  new  GWB  is  $92,500,  which  is  your  GWB  prior  to the
               withdrawal ($100,000) less the amount of the withdrawal ($7,500).

          o    Your GAWA for the next year remains $5,000, since your withdrawal
               did not exceed  the  greater  of your GAWA  ($5,000)  or your RMD
($7,500).                                         

          o    If you continued to take annual  withdrawals  equal to your GAWA,
               it would take an additional 19 years,  prior to the Latest Income
               Date, to deplete your GWB ($92,500 / $5,000 per year = 19 years),
               provided that there are no further  adjustments  made to your GWB
               or your GAWA  (besides  the annual  reduction  of your GWB by the
               amount of the withdrawal) and the amount of the final  withdrawal
               would be less than your GAWA (and equal to your remaining GWB) if
               your endorsement is not a For Life GMWB or if your endorsement is
               a For  Life  GMWB and the For Life  Guarantee  is not in  effect.
               However,  if you have  elected  a For Life  GMWB and the For Life
               Guarantee  is in  effect,  withdrawals  equal to your GAWA  could
               continue  for the rest of your  life (or  until  the death of the
               last  surviving  Covered Life if your  endorsement  is a For Life
               GMWB with  Joint  Option),  even  beyond  19 years,  prior to the
Latest Income Date.                               

o    Notes:                                                           

          o    If your  endorsement  includes a  Guaranteed  Withdrawal  Balance
               Bonus  provision,  your bonus base  remains  unchanged  since the
               withdrawal  did not exceed the  guaranteed  amount;  however,  no
               bonus will be applied to your GWB at the end of the Contract Year
in which the withdrawal is taken.                 

          o    If your  endorsement  does not include a For Life Guarantee or if
               the For Life  Guarantee is not in effect,  your GAWA would not be
permitted to exceed your new GWB.                 

          o    Withdrawals  taken in connection  with a GMWB are  considered the
               same as any other  withdrawal for the purpose of determining  all
               other values under the  Contract.  In the case where your minimum
               death benefit is reduced  proportionately  for withdrawals,  your
               death  benefit  may be  reduced  by more  than the  amount of the
withdrawal.                                       

EXAMPLE 4: UPON WITHDRAWAL OF AN AMOUNT THAT EXCEEDS YOUR GUARANTEED AMOUNT (AS 
DEFINED IN EXAMPLE 3), YOUR GWB AND GAWA ARE RE-DETERMINED.                     

     o    Example 4a: If you withdraw an amount ($10,000) that exceeds your GAWA
          ($5,000)  when  your  Contract  Value  is  $120,000  and  your  GWB is
$100,000:                                                   

          o    Your new GWB is $90,000, which is the lesser of 1) your GWB prior
               to the withdrawal  less the amount of the withdrawal  ($100,000 -
               $10,000  =  $90,000)  or 2)  your  Contract  Value  prior  to the
               withdrawal less the amount of the withdrawal  ($120,000 - $10,000
= $110,000).                                      

          o    Your GAWA is  recalculated  based on the type of endorsement  you
               have elected  and/or the effective  date of the  endorsement.  In
               addition,  if you have  elected  a For Life  GMWB,  your For Life
               Guarantee may be impacted  depending on the effective date of the
endorsement.                                      

               -    If your  endorsement  is a For Life  GMWB  and is  effective
                    prior to 05/01/2006 or if your endorsement is not a For Life
                    GMWB, your GAWA for the next year remains  $5,000,  since it
                    is recalculated to equal the lesser of 1) your GAWA prior to
                    the  withdrawal  ($5,000)  or 2) 5% of your  Contract  Value
                    after  the  withdrawal  ($110,000*0.05  =  $5,500).  If  you
                    continued to take annual  withdrawals equal to your GAWA, it
                    would  take an  additional  18  years,  prior to the  Latest
                    Income Date,  to deplete your GWB ($90,000 / $5,000 per year
                    = 18 years),  provided that there are no further adjustments
                    made to your GWB or your GAWA (besides the annual  reduction
                    of your GWB by the amount of the  withdrawal).  In addition,
                    if you have elected a For Life GMWB, your For Life Guarantee
                    becomes  null and void  since the  amount of the  withdrawal
exceeds your GAWA.                      

               -    If your  endorsement  is a For Life GMWB and is effective on
                    or after  05/01/2006,  your  GAWA is  recalculated  to equal
                    $4,500, which is 5% of your new GWB ($90,000*0.05 = $4,500),
                    and if the For Life  Guarantee  was  effective  prior to the
                    withdrawal,  it remains in effect.  If you continued to take
                    annual  withdrawals  equal to your  GAWA,  it would  take an
                    additional  20 years,  prior to the Latest  Income Date,  to
                    deplete  your GWB  ($90,000  / $4,500  per year = 20 years),
                    provided that there are no further  adjustments made to your
                    GWB or your GAWA  (besides the annual  reduction of your GWB
                    by the amount of the withdrawal).  However, if your For Life
                    Guarantee is in effect, withdrawals equal to your GAWA could
                    continue  for the rest of your life (or in the case of Joint
                    Owners,  until the first death of the Joint  Owners or until
                    the  death  of the  last  surviving  Covered  Life  if  your
                    endorsement  is a For Life GMWB  with  Joint  Option),  even
         beyond 20 years, prior to the Latest Income Date.

          o    If your  endorsement  includes a  Guaranteed  Withdrawal  Balance
               Bonus provision and your bonus base is $100,000 just prior to the
               withdrawal,  your bonus base is  recalculated  to equal  $90,000,
               which is the lesser of 1) your bonus base prior to the withdrawal
               ($100,000) or 2) your GWB following the withdrawal ($90,000).  In
               addition,  no bonus will be applied to your GWB at the end of the
Contract Year in which the withdrawal is taken.   

     o    Example 4b: If you withdraw an amount ($10,000) that exceeds your GAWA
          ($5,000)  when  your  Contract  Value  is  $105,000  and  your  GWB is
$100,000:                                                   

          o    Your new GWB is $90,000, which is the lesser of 1) your GWB prior
               to the withdrawal  less the amount of the withdrawal  ($100,000 -
               $10,000  =  $90,000)  or 2)  your  Contract  Value  prior  to the
               withdrawal less the amount of the withdrawal  ($105,000 - $10,000
= $95,000).                                       

          o    Your GAWA is  recalculated  based on the type of endorsement  you
               have elected  and/or the effective  date of the  endorsement.  In
               addition,  if you have  elected  a For Life  GMWB,  your For Life
               Guarantee may be impacted  depending on the effective date of the
endorsement.                                      

               -    If your  endorsement  is a For Life  GMWB  and is  effective
                    prior to 05/01/2006 or if your endorsement is not a For Life
                    GMWB,  your GAWA for the next year is  recalculated to equal
                    $4,750,  which is the  lesser of 1) your  GAWA  prior to the
                    withdrawal  ($5,000) or 2) 5% of your  Contract  Value after
                    the withdrawal  ($95,000*0.05 = $4,750). If you continued to
                    take annual withdrawals equal to your GAWA, it would take an
                    additional  19 years,  prior to the Latest  Income Date,  to
                    deplete  your GWB  ($90,000  / $4,750  per year = 19 years),
                    provided that there are no further  adjustments made to your
                    GWB or your GAWA  (besides the annual  reduction of your GWB
                    by the  amount  of the  withdrawal)  and the  amount of your
                    final  withdrawal would be less than your GAWA (and equal to
                    your remaining GWB). In addition,  if you have elected a For
                    Life GMWB,  your For Life  Guarantee  becomes  null and void
             since the amount of the withdrawal exceeds your GAWA.

               -    If your  endorsement  is a For Life GMWB and is effective on
                    or after  05/01/2006,  your  GAWA is  recalculated  to equal
                    $4,500, which is 5% of your new GWB ($90,000*0.05 = $4,500),
                    and if the For Life  Guarantee  was  effective  prior to the
                    withdrawal,  it remains in effect.  If you continued to take
                    annual  withdrawals  equal to your  GAWA,  it would  take an
                    additional  20 years,  prior to the Latest  Income Date,  to
                    deplete  your GWB  ($90,000  / $4,500  per year = 20 years),
                    provided that there are no further  adjustments made to your
                    GWB or your GAWA  (besides the annual  reduction of your GWB
                    by the amount of the withdrawal).  However, if your For Life
                    Guarantee is in effect, withdrawals equal to your GAWA could
                    continue  for the rest of your life (or in the case of Joint
                    Owners,  until the first death of the Joint  Owners or until
                    the  death  of the  last  surviving  Covered  Life  if  your
                    endorsement  is a For Life GMWB  with  Joint  Option),  even
         beyond 20 years, prior to the Latest Income Date.

               o    If your endorsement includes a Guaranteed Withdrawal Balance
                    Bonus  provision  and your bonus base is $100,000 just prior
                    to the withdrawal,  your bonus base is recalculated to equal
                    $90,000,  which is the lesser of 1) your bonus base prior to
                    the  withdrawal  ($100,000)  or 2) your  GWB  following  the
                    withdrawal ($90,000).  In addition, no bonus will be applied
                    to your GWB at the end of the  Contract  Year in  which  the
withdrawal is taken.                    

     o    Example 4c: If you withdraw an amount ($10,000) that exceeds your GAWA
          ($5,000) when your Contract Value is $90,000 and your GWB is $100,000:

          o    Your new GWB is $80,000, which is the lesser of 1) your GWB prior
               to the withdrawal  less the amount of the withdrawal  ($100,000 -
               $10,000  =  $90,000)  or 2)  your  Contract  Value  prior  to the
               withdrawal less the amount of the withdrawal ($90,000 - $10,000 =
$80,000).                                         

          o    Your GAWA is  recalculated  based on the type of endorsement  you
               have elected  and/or the effective  date of the  endorsement.  In
               addition,  if you have  elected  a For Life  GMWB,  your For Life
               Guarantee may be impacted  depending on the effective date of the
endorsement.                                      

          -    If your  endorsement is a For Life GMWB and is effective prior to
               05/01/2006 or if your  endorsement  is not a For Life GMWB,  your
               GAWA for the next year is recalculated to equal $4,000,  which is
               the lesser of 1) your GAWA prior to the withdrawal ($5,000) or 2)
               5% of your Contract  Value after the withdrawal  ($80,000*0.05  =
               $4,000).  If you  continued to take annual  withdrawals  equal to
               your GAWA,  it would take an  additional  20 years,  prior to the
               Latest  Income  Date,  to deplete  your GWB ($80,000 / $4,000 per
               year = 20 years),  provided that there are no further adjustments
               made to your GWB or your GAWA  (besides  the annual  reduction of
               your GWB by the amount of the  withdrawal).  In addition,  if you
               have  elected a For Life GMWB,  your For Life  Guarantee  becomes
               null and void since the  amount of the  withdrawal  exceeds  your
GAWA.                                             

          -    If your  endorsement  is a For Life GMWB and is  effective  on or
               after  05/01/2006,  your GAWA is  recalculated  to equal  $4,000,
               which is 5% of your new GWB  ($80,000*0.05 = $4,000),  and if the
               For Life  Guarantee was  effective  prior to the  withdrawal,  it
               remains in effect.  If you  continued to take annual  withdrawals
               equal to your GAWA, it would take an  additional 20 years,  prior
               to the Latest  Income Date, to deplete your GWB ($80,000 / $4,000
               per  year  = 20  years),  provided  that  there  are  no  further
               adjustments  made to your GWB or your GAWA  (besides  the  annual
               reduction of your GWB by the amount of the withdrawal).  However,
               if your For Life  Guarantee  is in effect,  withdrawals  equal to
               your  GAWA  could  continue  for the rest of your life (or in the
               case of Joint  Owners,  until the first death of the Joint Owners
               or until the  death of the last  surviving  Covered  Life if your
               endorsement is a For Life GMWB with Joint Option), even beyond 20
years, prior to the Latest Income Date.           

          o    If your  endorsement  includes a  Guaranteed  Withdrawal  Balance
               Bonus provision and your bonus base is $100,000 just prior to the
               withdrawal,  your bonus base is  recalculated  to equal  $80,000,
               which is the lesser of 1) your bonus base prior to the withdrawal
               ($100,000) or 2) your GWB following the withdrawal ($80,000).  In
               addition,  no bonus will be applied to your GWB at the end of the
Contract Year in which the withdrawal is taken.   

o    Notes:                                                           

          o    If your  endorsement  does not include a For Life Guarantee or if
               the For Life  Guarantee is not in effect,  your GAWA would not be
permitted to exceed your remaining GWB.           

          o    Withdrawals  taken in connection  with a GMWB are  considered the
               same as any other  withdrawal for the purpose of determining  all
               other values under the  Contract.  In the case where your minimum
               death benefit is reduced  proportionately  for withdrawals,  your
               death  benefit  may be  reduced  by more  than the  amount of the
withdrawal.                                       

EXAMPLE 5: UPON STEP-UP, YOUR GWB AND GAWA ARE RE-DETERMINED. (THIS EXAMPLE ONLY
APPLIES IF YOUR ENDORSEMENT CONTAINS A GUARANTEED WITHDRAWAL BALANCE STEP-UP    
PROVISION.)                                                                     

     o    Example 5a: If at the time of step-up your Contract Value is $200,000,
your GWB is $100,000 and your GAWA is $5,000:               

          o    Your new GWB is recalculated to equal $200,000, which is equal to
your Contract Value.                              

          o    Your GAWA for the next  year is  recalculated  to equal  $10,000,
               which  is the  greater  of 1)  your  GAWA  prior  to the  step-up
          ($5,000) or 2) 5% of your new GWB ($200,000*0.05 = $10,000).

          o    If your  endorsement  includes a  Guaranteed  Withdrawal  Balance
               Bonus  provision  your bonus base is  $100,000  just prior to the
               step-up, your bonus base is recalculated to equal $200,000, which
               is the  greater  of 1)  your  bonus  base  prior  to the  step-up
         ($100,000) or 2) your GWB following the step-up ($200,000).

          o    After step-up,  if you continued to take annual withdrawals equal
               to your GAWA, it would take an additional 20 years,  prior to the
               Latest  Income Date,  to deplete your GWB ($200,000 / $10,000 per
               year = 20 years),  provided that there are no further adjustments
               made to your GWB or your GAWA  (besides  the annual  reduction of
               your GWB by the amount of the withdrawal).  However,  if you have
               elected a For Life GMWB and the For Life  Guarantee is in effect,
               withdrawals  equal to your GAWA  could  continue  for the rest of
               your life (or in the case of Joint Owners,  until the first death
               of the Joint  Owners  or until  the  death of the last  surviving
               Covered  Life if your  endorsement  is a For Life GMWB with Joint
             Option), even beyond 20 years, prior to the Latest Income Date.

     o    Example 5b: If at the time of step-up your Contract  Value is $90,000,
your GWB is $80,000 and your GAWA is $5,000:                

          o    Your new GWB is recalculated to equal $90,000,  which is equal to
your Contract Value.                              

          o    Your GAWA for the next year remains $5,000,  which is the greater
               of 1) your GAWA prior to the  step-up  ($5,000)  or 2) 5% of your
new GWB ($90,000*0.05 = $4,500).                  

o        If your endorsement includes a Guaranteed Withdrawal Balance Bonus     
      provision and your bonus base is $100,000 just prior to the step-up,
         your bonus base remains $100,000, which is the greater of 1) your bonus
   base prior to the step-up ($100,000) or 2) your GWB following the
step-up ($90,000).                                            

o        After step-up, if you continued to take annual withdrawals equal to    
      your GAWA, it would take an additional 18 years, prior to the Latest
  Income Date, to deplete your GWB ($90,000 / $5,000 per year = 18
         years), provided that there are no further adjustments made to your GWB
         or your GAWA (besides the annual reduction of your GWB by the amount of
       the withdrawal). However, if you have elected a For Life GMWB and the
       For Life Guarantee is in effect, withdrawals equal to your GAWA could
     continue for the rest of your life (or in the case of Joint Owners,
     until the first death of the Joint Owners or until the death of the
         last surviving Covered Life if your endorsement is a For Life GMWB with
       Joint Option), even beyond 18 years, prior to the Latest Income Date.

o        Notes:                                                                 

          o    If your  endorsement  contains a  provision  for  Owner-initiated
               step-ups,  the election of an Owner-initiated  step-up may result
               in an increase in the GMWB charge. If the charge does increase, a
               separate  calculation  would be  recommended  to establish if the
step-up is a beneficial election.                 

          o    If your endorsement  contains a provision for automatic step-ups,
               your GWB will only step up to the Contract  Value if the Contract
               Value is  greater  than  your  GWB at the  time of the  automatic
step-up.                                          

          o    If your  endorsement  contains a  Guaranteed  Withdrawal  Balance
               Bonus  provision  and a provision for  automatic  step-ups,  your
               bonus base will be  re-determined  only if your GWB is  increased
               upon  step-up to a value  above your bonus base just prior to the
step-up.                                          

EXAMPLE 6: IMPACT OF THE ORDER OF TRANSACTIONS. (THIS EXAMPLE ONLY APPLIES IF   
YOUR ENDORSEMENT CONTAINS A GUARANTEED WITHDRAWAL BALANCE STEP-UP PROVISION.)   

     o    If prior to any transactions your Contract Value is $200,000, your GWB
          is  $100,000  and you  wish to step up your GWB (or your GWB is due to
          step up  automatically)  and you also wish to take a withdrawal  of an
amount equal to your GAWA ($5,000):                         

     o    If you request the withdrawal  after the step-up,  upon step-up,  your
          GWB is set equal to $200,000,  which is your Contract  Value.  At that
          time, your GAWA is recalculated and is equal to $10,000,  which is the
          greater of 1) your GAWA prior to the step-up ($5,000) or 2) 5% of your
          new GWB ($200,000*0.05 = $10,000). Following the step-up and after the
          withdrawal of $5,000, your new GWB is $195,000, which is your GWB less
          the amount of the  withdrawal  ($200,000 - $5,000 = $195,000) and your
          GAWA will remain at $10,000  since the amount of the  withdrawal  does
          not exceed your GAWA.  If you  continued  to take  annual  withdrawals
          equal to your GAWA, it would take an additional 20 years, prior to the
          Latest Income Date, to deplete your GWB ($195,000 / $10,000 per year =
          20 years), provided that there are no further adjustments made to your
          GWB or your GAWA  (besides  the  annual  reduction  of your GWB by the
          amount of the withdrawal) and the amount of the final withdrawal would
          be less than your GAWA (and equal to your remaining GWB).  However, if
          you have  elected  a For Life  GMWB and the For Life  Guarantee  is in
          effect,  withdrawals equal to your GAWA could continue for the rest of
          your life (or in the case of Joint  Owners,  until the first  death of
          the Joint Owners or until the death of the last surviving Covered Life
          if your endorsement is a For Life GMWB with Joint Option), even beyond
20 years, prior to the Latest Income Date.                  

          o    If your  endorsement  contains a  Guaranteed  Withdrawal  Balance
               Bonus provision and your bonus base is $100,000 just prior to the
               step-up, at the time of step-up,  your bonus base is recalculated
               and is equal to  $200,000,  which is the greater of 1) your bonus
               base prior to the step-up ($100,000) or 2) your GWB following the
               step-up  ($200,000).   Your  bonus  base  is  not  adjusted  upon
               withdrawal  since the  amount of the  withdrawal  does not exceed
your GAWA.                                        

     o    If you  requested  the  withdrawal  prior to the step-up,  immediately
          following the withdrawal  transaction,  your new GWB is $95,000, which
          is your GWB less the  amount of the  withdrawal  ($100,000  - $5,000 =
          $95,000)  and your  Contract  Value  becomes  $195,000,  which is your
          Contract  Value  prior  to  the  withdrawal  less  the  amount  of the
          withdrawal ($200,000 - $5,000 = $195,000).  Upon step-up following the
          withdrawal,  your GWB is set equal to $195,000, which is your Contract
          Value. At that time, your GAWA is recalculated and is equal to $9,750,
          which is the greater of 1) your GAWA prior to the step-up  ($5,000) or
          2) 5% of your new GWB  ($195,000*0.05  = $9,750).  If you continued to
          take  annual  withdrawals  equal  to  your  GAWA,  it  would  take  an
          additional 20 years,  prior to the Latest Income Date, to deplete your
          GWB  ($195,000 / $9,750 per year = 20 years),  provided that there are
          no  further  adjustments  made to your GWB or your GAWA  (besides  the
          annual  reduction  of  your  GWB by  the  amount  of the  withdrawal).
          However,  if you  have  elected  a For  Life  GMWB  and the  For  Life
          Guarantee is in effect,  withdrawals equal to your GAWA could continue
          for the rest of your life (or in the case of Joint  Owners,  until the
          first  death  of the  Joint  Owners  or  until  the  death of the last
          surviving  Covered  Life if your  endorsement  is a For Life GMWB with
         Joint Option), even beyond 20 years, prior to the Latest Income Date.

          o    If your  endorsement  contains a  Guaranteed  Withdrawal  Balance
               Bonus provision and your bonus base is $100,000 just prior to the
               step-up,  at the time of the  withdrawal,  your bonus base is not
               adjusted since the amount of the withdrawal  does not exceed your
               GAWA. At the time of step-up, your bonus base is recalculated and
               is equal to $195,000,  which is the greater of 1) your bonus base
               prior to the  step-up  ($100,000)  or 2) your GWB  following  the
step-up ($195,000).                               

o    Notes:                                                           

          o    As the  example  illustrates,  when  considering  a request for a
               withdrawal  at or near the same time as the election or automatic
               application  of a  step-up,  the  order of the  transactions  may
               impact your GAWA.  If the step-up  would result in an increase in
               your GAWA and the  requested  withdrawal is less than or equal to
               your new GAWA,  your GAWA  resulting  after the two  transactions
               would be greater if the withdrawal is requested after the step-up
               is applied.  If the step-up  does not  increase  your GAWA or the
               withdrawal  requested  is greater  than your new GAWA,  your GAWA
               resulting  from the  transactions  is the same  regardless of the
order of the transactions.                        

          o    This example would also apply in situations  when the  withdrawal
exceeded your GAWA but not your permissible RMD.  

          o    If your  endorsement  contains a  provision  for  Owner-initiated
               step-ups,  the election of an Owner-initiated  step-up may result
in an increase in the GMWB charge.                

          o    If your endorsement  contains a provision for automatic step-ups,
               your GWB will only step up to the Contract  Value if the Contract
               Value is  greater  than  your  GWB at the  time of the  automatic
step-up.                                          

          o    If your  endorsement  contains a  Guaranteed  Withdrawal  Balance
               Bonus  provision  and a provision for  automatic  step-ups,  your
               bonus base will be  re-determined  only if your GWB is  increased
               upon  step-up to a value  above your bonus base just prior to the
step-up.                                          

          o    If your  endorsement  does not include a For Life Guarantee or if
               the For Life  Guarantee is not in effect,  your GAWA would not be
permitted to exceed your remaining GWB.           

          o    Withdrawals  taken in connection  with a GMWB are  considered the
               same as any other  withdrawal for the purpose of determining  all
               other values under the  Contract.  In the case where your minimum
               death benefit is reduced  proportionately  for withdrawals,  your
               death  benefit  may be  reduced  by more  than the  amount of the
withdrawal.                                       

EXAMPLE 7: UPON APPLICATION OF THE GUARANTEED WITHDRAWAL BALANCE BONUS, YOUR GWB
AND GAWA ARE RE-DETERMINED. (THIS EXAMPLE ONLY APPLIES IF YOUR ENDORSEMENT      
CONTAINS A GUARANTEED WITHDRAWAL BALANCE BONUS PROVISION.)                      

     o    Example  7a: If at the end of a Contract  Year in which you have taken
          no withdrawals, your GWB is $100,000, your bonus base is $100,000, and
your GAWA is $5,000:                                        

          o    Your new GWB is recalculated to equal $105,000, which is equal to
               your GWB plus 5% of your bonus base ($100,000 +  $100,000*0.05  =
$105,000).                                        

          o    Your  GAWA for the next  year is  recalculated  to equal  $5,250,
               which is the greater of 1) your GAWA prior to the  application of
               the  bonus  ($5,000)  or 2) 5% of your new GWB  ($105,000*0.05  =
$5,250).                                          

          o    After the  application  of the bonus,  if you  continued  to take
               annual   withdrawals  equal  to  your  GAWA,  it  would  take  an
               additional 20 years,  prior to the Latest Income Date, to deplete
               your GWB  ($105,000 / $5,250 per year = 20 years),  provided that
               there are no  further  adjustments  made to your GWB or your GAWA
               (besides  the annual  reduction  of your GWB by the amount of the
               withdrawal). However, if you have elected a For Life GMWB and the
               For Life Guarantee is in effect,  withdrawals  equal to your GAWA
               could continue for the rest of your life (or in the case of Joint
               Owners,  until the first  death of the Joint  Owners or until the
               death of the last surviving Covered Life if your endorsement is a
               For Life GMWB with Joint Option),  even beyond 20 years, prior to
the Latest Income Date.                           

     o    Example  7b: If at the end of a Contract  Year in which you have taken
          no withdrawals,  your GWB is $90,000, your bonus base is $100,000, and
your GAWA is $5,000:                                        

          o    Your new GWB is recalculated to equal $95,000,  which is equal to
               your GWB plus 5% of your bonus base  ($90,000 +  $100,000*0.05  =
$95,000).                                         

          o    Your GAWA for the next year remains $5,000,  which is the greater
               of 1) your GAWA prior to the application of the bonus ($5,000) or
2) 5% of your new GWB ($95,000*0.05 = $4,750).    

          o    After the  application  of the bonus,  if you  continued  to take
               annual   withdrawals  equal  to  your  GAWA,  it  would  take  an
               additional 19 years,  prior to the Latest Income Date, to deplete
               your GWB  ($95,000 / $5,000 per year = 19 years),  provided  that
               there are no  further  adjustments  made to your GWB or your GAWA
               (besides  the annual  reduction  of your GWB by the amount of the
               withdrawal). However, if you have elected a For Life GMWB and the
               For Life Guarantee is in effect,  withdrawals  equal to your GAWA
               could continue for the rest of your life (or in the case of Joint
               Owners,  until the first  death of the Joint  Owners or until the
               death of the last surviving Covered Life if your endorsement is a
               For Life GMWB with Joint Option),  even beyond 19 years, prior to
the Latest Income Date.                           

o    Notes:                                                           

          o    Your bonus base is not  recalculated  upon the application of the
bonus to your GWB.                                

EXAMPLE 8: FOR LIFE GUARANTEE BECOMES EFFECTIVE AFTER THE EFFECTIVE DATE OF THE 
ENDORSEMENT. AT THE TIME THE FOR LIFE GUARANTEE BECOMES EFFECTIVE, YOUR GAWA IS 
RE-DETERMINED. (THIS EXAMPLE ONLY APPLIES IF YOUR ENDORSEMENT IS A FOR LIFE GMWB
EFFECTIVE ON OR AFTER 05/01/2006.)                                              

     o    Example 8a: If on the Contract Anniversary on or immediately following
          your  65th  birthday  your  Contract  Value  is  $30,000,  your GWB is
$50,000, and your GAWA is $5,000:                           

          o    Your  GAWA for the next  year is  recalculated  to equal  $2,500,
              which is equal to 5% of the current GWB ($50,000*0.05 = $2,500).

          o    The For Life Guarantee  becomes  effective,  thus allowing you to
               make annual  withdrawals  equal to your GAWA for the rest of your
               life (or in the case of Joint  Owners,  until the first  death of
               the Joint Owners or until the death of the last surviving Covered
               Life if your  endorsement  is a For Life GMWB with Joint Option).
               Once the For Life  Guarantee  becomes  effective,  it  remains in
               effect until the  endorsement is terminated,  as described in the
               Access  to  Your  Money  section  of  this  prospectus,  or  upon
               continuation   of  the  Contract  by  the  spouse   (unless  your
               endorsement  is a For Life GMWB with Joint  Option and the spouse
               continuing  the  Contract is a Covered Life in which case the For
               Life  Guarantee  remains  in  effect  upon  continuation  of  the
Contract by the spouse).                          

     o    Example  8b:  If your  Contract  Value  has  fallen to $0 prior to the
          Contract  Anniversary on or immediately  following your 65th birthday,
your GWB is $50,000 and your GAWA is $5,000:                

          o    You will continue to receive automatic payments of a total annual
               amount that equals your GAWA until your GWB is depleted. However,
               your GAWA would not be  permitted to exceed your  remaining  GWB.
           Your GAWA is not recalculated since the Contract Value is $0.

          o    The For Life  Guarantee  does  not  become  effective  due to the
               depletion of the Contract  Value prior to the  effective  date of
the For Life Guarantee.                           

     o    Example 8c: If on the Contract Anniversary on or immediately following
          your 65th birthday,  your Contract  Value is $50,000,  your GWB is $0,
and your GAWA is $5,000:                                    

          o    Your GAWA for the next year is recalculated to equal $0, which is
equal to 5% of the current GWB ($0*0.05 = $0).    

               o    The For Life Guarantee becomes effective,  thus allowing you
                    to make annual  withdrawals  equal to your GAWA for the rest
                    of your  life  (or in the case of Joint  Owners,  until  the
                    first  death of the  Joint  Owners or until the death of the
                    last  surviving  Covered Life if your  endorsement  is a For
                    Life GMWB with Joint  Option).  Once the For Life  Guarantee
                    becomes   effective,   it  remains   in  effect   until  the
                    endorsement  is  terminated,  as  described in the Access to
                    Your Money section of this prospectus,  or upon continuation
                    of the Contract by the spouse (unless your  endorsement is a
                    For Life GMWB with Joint  Option  and the spouse  continuing
                    the  Contract  is a Covered  Life in which case the For Life
                    Guarantee   remains  in  effect  upon  continuation  of  the
Contract by the spouse).                

               o    Although your GAWA is $0, upon step-up or subsequent premium
                    payments,  your GWB and your GAWA would  increase  to values
                    greater than $0 and since the For Life  Guarantee has become
                    effective, you could withdraw an annual amount equal to your
                    GAWA  for the  rest of your  life  (or in the  case of Joint
                    Owners,  until the first death of the Joint  Owners or until
                    the  death  of the  last  surviving  Covered  Life  if  your
          endorsement is a For Life GMWB with Joint Option).

o    Notes:                                                           

          o    For endorsements  with a Joint Option,  your GAWA is recalculated
               and the For Life  Guarantee  becomes  effective  on the  Contract
               Anniversary  on or  immediately  following  the youngest  Covered
Life's 65th birthday.                             

EXAMPLE 9: FOR LIFE GUARANTEE ON A FOR LIFE GMWB WITH JOINT OPTION. (THIS       
EXAMPLE ONLY APPLIES IF YOUR ENDORSEMENT IS A FOR LIFE GMWB WITH JOINT OPTION.) 

     o    If at the time of death of the  Owner  (or  either  Joint  Owner)  the
          Contract  Value is $105,000,  your GWB is  $100,000,  and your GAWA is
$5,000:                                                     

          o    The surviving  Covered Life may continue the Contract and the For
               Life Guarantee  will remain in effect or become  effective on the
               Contract  Anniversary on or  immediately  following the date that
               the youngest  Covered Life attains (or would have  attained)  age
               65. Once the For Life Guarantee becomes effective,  the surviving
               Covered Life will be able to take annual withdrawals equal to the
GAWA for the rest of his or her life.             

          o    The  surviving  spouse who is not a Covered Life may continue the
               Contract and the For Life  Guarantee  is null and void.  However,
               the surviving spouse will be entitled to make  withdrawals  until
the GWB is exhausted.                             

o    Your GWB remains $100,000 and your GAWA remains $5,000.

o    Notes:                                                           

          o    If your  endorsement  contains a  Guaranteed  Withdrawal  Balance
               Bonus provision, your bonus base remains unchanged at the time of
continuation.                                     

--------------------------------------------------------------------------------
*    On the last page of the prospectus,  please replace the corresponding  text
box with the following.                                               

                                                        [Enlarge/Download Table]

                                                                                                             

-------------------------------------------------------------------------------------------------------------
QUESTIONS:  If you have any questions about your Contract, you may contact us at:                            

JACKSON OF NY SERVICE CENTER:                          1 (800) 599-5651 (8 a.m. - 8 p.m. ET)                 

            MAIL ADDRESS:                              P.O. Box 378004, Denver, Colorado 80237-8004          

            DELIVERY ADDRESS:                          7601 Technology Way, Denver, Colorado 80237           

JACKSON OF NY IMG SERVICE CENTER:                      1 (888) 464-7779 (8 a.m. - 8 p.m. ET)                 
(for Contracts purchased through a bank                                                                      
or another financial institution)                                                                            

            MAIL ADDRESS:                              P.O. Box 33178, Detroit, MI 48232-5178                

            DELIVERY ADDRESS:                          c/o Standard Federal Bank, Drawer 5178,               
                                                       12425 Merriman Road, Livonia, MI 48150                

HOME OFFICE:                                           2900 Westchester Avenue, Purchase, New York 10577     
-------------------------------------------------------------------------------------------------------------

(To be used with NV4224 Rev. 05/06)                                             
                                                                    NV6056 12/06

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SUPPLEMENT DATED DECEMBER 22, 2006
TO THE STATEMENT OF ADDITIONAL INFORMATION DATED MAY 1, 2006 FOR

 PERSPECTIVE II(R)
PERSPECTIVESM L SERIES
PERSPECTIVE FOCUS(R)

ISSUED BY JACKSON NATIONAL LIFE INSURANCE COMPANY(R)
 THROUGH JACKSON NATIONAL SEPARATE ACCOUNT - I

 OR ISSUED BY JACKSON NATIONAL LIFE INSURANCE COMPANY OF NEW YORK(R)
THROUGH JNLNY SEPARATE ACCOUNT I

THIS  SUPPLEMENT  UPDATES THE  STATEMENT OF  ADDITIONAL  INFORMATION,  EFFECTIVE
JANUARY  16,  2007.  PLEASE  READ AND KEEP IT  TOGETHER  WITH  YOUR  COPY OF THE
STATEMENT OF ADDITIONAL INFORMATION FOR FUTURE REFERENCE.                       
--------------------------------------------------------------------------------

*    Under UNDERWRITERS, please replace the first paragraph as follows:         

       The Contracts are offered continuously and are distributed by Jackson
     National Life Distributors LLC (JNLD), 7601 Technology Way, Denver,
Colorado 80237. JNLD is a subsidiary of Jackson National.     

*    Under   ADDITIONAL   TAX   INFORMATION,    in   the   subsection   entitled
     "Diversification  --  Separate  Account  Investments,"  please  replace the
second to the last paragraph with the following.                      

       Like the contracts described in Rev. Rul. 2003-91, under the Contract
     there will be no arrangement, plan, contract or agreement between a
Contract owner and Jackson National Life of NY regarding the  
   availability of a particular Allocation Option and other than the
      Contract owner's right to allocate premiums and transfer funds among
       the available Allocation Options, all investment decisions concerning
       the Allocation Options will be made by Jackson National Life of NY or
   an advisor in its sole and absolute discretion. The Contract will
 differ from the contracts described in Rev. Rul. 2003-91 in two
        respects. The first difference is that the contracts described in Rev.
     Rul. 2003-91 provided only 12 investment options with the insurance
       company having the ability to add an additional 8 options whereas the
        Contract offers 76 Investment Divisions and 1 Fixed Account although a
         Contract owner can select no more than 18 Allocation Options at any one
     time. The second difference is that the owner of a contract in Rev.
       Rul. 2003-91 could only make one transfer per 30-day period without a
         fee whereas during the accumulation phase, a Contract owner can make 15
transfers in any one year without a charge.                   

(To be used with NV5639 05/06, V5913 05/06, NV5913 05/06, V5596 05/06 and NV5661
05/06)                                                                          

                                                                     V6067 12/06

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PART C. OTHER INFORMATION                                                       

Item 24.       Financial Statements and Exhibits                                

(a)   Financial Statements:                       

                    (1) Financial statements and schedules included in Part A:

       Condensed Financial Information

                     (2) Financial statements and schedules included in Part B -
                 incorporated by reference to Registrant's Post-
                     Effective Amendment No. 23, filed on April 27, 2006
      (File Nos. 333-70384 and 811-08401):

JNLNY Separate Account I

                          Report of Independent Registered Public Accounting
Firm                
                  Statements of Assets and Liabilities as of
December 31, 2005   
                     Statements of Operations for the period ended
December 31, 2005   
                          Statements of Changes in Net Assets for the period
            ended December 31, 2005 and 2004
     Notes to Financial Statements

                           Jackson National Life Insurance Company of New York

                          Report of Independent Registered Public Accounting
Firm                
                       Balance Sheets for the years ended December 31,
2005 and 2004       
                          Income Statements for the years ended December 31,
2005, 2004 and 2003 
                            Statements of Stockholder's Equity and Comprehensive
                         Income for the years ended December 31, 2005,
2004 and 2003       
                    Statements of Cash Flows for the years ended
            December 31, 2005, 2004 and 2003
     Notes to Financial Statements

Item 24.(b)        Exhibits                                                     

Exhibit No.        Description                                                  

1.                 Resolution of Depositor's Board of Directors authorizing the 
                   establishment of the Registrant, incorporated by reference to
                  Registrant's Registration Statement filed on October 3, 1997
(File Nos. 333-37175 and 811-08401).      

2.                 Not Applicable                                               

3.a                General Distributor Agreement dated September 19, 1997,      
            incorporated by reference to Registrant's Registration
                 Statement filed on October 3, 1997 (File Nos. 333-37175 and
811-08401).                               

b.                 General Distributor Agreement dated June 30, 1998,           
              incorporated by reference to Registrant's Post-Effective
                  Amendment No. 12 filed on July 22, 2004 (File Nos. 333-70384
and 811-08401).                           

c.                 Amended and Restated General Distributor Agreement dated     
        October 25, 2005, incorporated by reference to the
           Registrant's Post-Effective Amendment No. 21 filed on
            December 29, 2005 (File Nos. 333-70472 and 811-08664).

d.                 Amended and Restated General Distributor Agreement dated     
                 June 1, 2006, incorporated by reference to the Registrant's
                Registration Statement filed on August 10, 2006 (File Nos.
333-136472 and 811-08401).                

4.a.               Specimen of the Perspective II Fixed and Variable Annuity    
         Contract, incorporated by reference to Registrant's
                   Registration Statement filed on September 28, 2001 (File Nos.
333-70384 and 811-08401).                 

b.                 Specimen of Tax Sheltered Annuity Endorsement, incorporated  
                by reference to Registrant's Pre-Effective Amendment No. 1
         filed on December 19, 2001 (File Nos. 333-70384 and
811-08401).                               

c.                 Specimen of Retirement Plan Endorsement, incorporated by     
                   reference to Registrant's Pre-Effective Amendment No. 1 filed
               on December 19, 2001 (File Nos. 333-70384 and 811-08401).

d.                 Specimen of Individual Retirement Annuity Endorsement,       
             incorporated by reference to Registrant's Pre-Effective
           Amendment No. 1 filed on December 19, 2001 (File Nos.
333-70384 and 811-08401).                 

e.                 Specimen of Roth IRA Endorsement, incorporated by reference  
            to Registrant's Pre-Effective Amendment No. 1 filed on
            December 19, 2001 (File Nos. 333-70384 and 811-08401).

f.                 Specimen of Earnings Protection Benefit Endorsement,         
            incorporated by reference to Registrant's Registration
                Statement filed on September 28, 2001 (File Nos. 333-70384
and 811-08401).                           

g.                 Specimen of 2% Contract Enhancement Endorsement, incorporated
                  by reference to Registrant's Registration Statement filed on
             September 28, 2001 (File Nos. 333-70384 and 811-08401).

h.                 Specimen of 3% Contract Enhancement Endorsement, incorporated
                  by reference to Registrant's Registration Statement filed on
             September 28, 2001 (File Nos. 333-70384 and 811-08401).

i.                 Specimen of 4% Contract Enhancement Endorsement, incorporated
                  by reference to Registrant's Registration Statement filed on
             September 28, 2001 (File Nos. 333-70384 and 811-08401).

j.                 Specimen of 20% Additional Free Withdrawal Benefit           
            Endorsement, incorporated by reference to Registrant's
                   Registration Statement filed on September 28, 2001 (File Nos.
333-70384 and 811-08401).                 

k.                 Specimen of Five-Year Withdrawal Charge Schedule Endorsement,
            incorporated by reference to Registrant's Registration
                Statement filed on September 28, 2001 (File Nos. 333-70384
and 811-08401).                           

l.                 Specimen of Preselected Death Benefit Option Election        
            Endorsement, incorporated by reference to Registrant's
              Pre-Effective Amendment No. 1 filed on December 19, 2001
(File Nos. 333-70384 and 811-08401).      

m.                 Specimen of Reduced Administration Charge Endorsement,       
              incorporated by reference to Registrant's Post-Effective
                Amendment No. 1 filed on May 17, 2002 (File Nos. 333-70384
and 811-08401).                           

n.                 Specimen of 2% Contract Enhancement Endorsement, incorporated
                 by reference to Registrant's Post-Effective Amendment No. 1
                filed on May 17, 2002 (File Nos. 333-70384 and 811-08401).

o.                 Specimen of 3% Contract Enhancement Endorsement, incorporated
                 by reference to Registrant's Post-Effective Amendment No. 1
                filed on May 17, 2002 (File Nos. 333-70384 and 811-08401).

p.                 Specimen of 4% Contract Enhancement Endorsement, incorporated
                 by reference to Registrant's Post-Effective Amendment No. 1
                filed on May 17, 2002 (File Nos. 333-70384 and 811-08401).

q.                 Specimen of Guaranteed Minimum Income Benefit Endorsement,   
              incorporated by reference to Registrant's Post-Effective
                Amendment No. 2 filed on May 20, 2002 (File Nos. 333-70384
and 811-08401).                           

r.                 Specimen of Guaranteed Minimum Withdrawal Benefit            
            Endorsement, incorporated by reference to Registrant's
              Post-Effective Amendment No. 4 filed on November 1, 2002
(File Nos. 333-70384 and 811-08401).      

s.                 Specimen of Fixed Account Option Endorsement, incorporated by
              reference to Registrant's Post-Effective Amendment No. 4
        filed on November 1, 2002 (File Nos. 333-70384 and
811-08401).                               

t.                 Specimen of 3-Year Withdrawal Charge Schedule Endorsement,   
              incorporated by reference to Registrant's Post-Effective
                 Amendment No. 6 filed on June 20, 2003 (File Nos. 333-70384
and 811-08401).                           

u.                 Specimen of Guaranteed Minimum Income Benefit Endorsement,   
              incorporated by reference to Registrant's Post-Effective
                 Amendment No. 6 filed on June 20, 2003 (File Nos. 333-70384
and 811-08401).                           

v.                 Specimen of 2% Contract Enhancement Endorsement, incorporated
                 by reference to Registrant's Post-Effective Amendment No. 6
                 filed on June 20, 2003 (File Nos. 333-70384 and 811-08401).

w.                 Specimen of 3% Contract Enhancement Endorsement, incorporated
                 by reference to Registrant's Post-Effective Amendment No. 6
                 filed on June 20, 2003 (File Nos. 333-70384 and 811-08401).

x.                 Specimen of Maximum Anniversary Value Death Benefit          
            Endorsement, incorporated by reference to Registrant's
                 Post-Effective Amendment No. 6 filed on June 20, 2003 (File
Nos. 333-70384 and 811-08401).            

y.                 Specimen of 20% Additional Withdrawal Benefit Endorsement,   
              incorporated by reference to Registrant's Post-Effective
                 Amendment No. 6 filed on June 20, 2003 (File Nos. 333-70384
and 811-08401).                           

z.                 Specimen of 5 Year Withdrawal Charge Schedule Endorsement,   
              incorporated by reference to Registrant's Post-Effective
                 Amendment No. 6 filed on June 20, 2003 (File Nos. 333-70384
and 811-08401).                           

aa.                Specimen of the Perspective II Fixed and Variable Annuity    
         Contract, incorporated by reference to Registrant's
                 Post-Effective Amendment No. 6 filed on June 20, 2003 (File
Nos. 333-70384 and 811-08401).            

bb.                Specimen of Guaranteed Minimum Income Benefit Endorsement,   
              incorporated by reference to Registrant's Post-Effective
                   Amendment No. 11 filed on April 29, 2004 (File Nos. 333-70384
and 811-08401).                           

cc.                Specimen of the Perspective II Fixed and Variable Annuity    
         Contract, incorporated by reference to Registrant's
                  Post-Effective Amendment No. 12 filed on July 22, 2004 (File
Nos. 333-70384 and 811-08401).            

dd.                Specimen of 4% Contract Enhancement Endorsement, incorporated
                  by reference to Registrant's Post-Effective Amendment No. 12
                 filed on July 22, 2004 (File Nos. 333-70384 and 811-08401).

ee.                Specimen of 2% Contract Enhancement Endorsement, incorporated
                  by reference to Registrant's Post-Effective Amendment No. 12
                 filed on July 22, 2004 (File Nos. 333-70384 and 811-08401).

ff.                Specimen of 3% Contract Enhancement Endorsement, incorporated
                  by reference to Registrant's Post-Effective Amendment No. 12
                 filed on July 22, 2004 (File Nos. 333-70384 and 811-08401).

gg.                Specimen of 20% Additional Withdrawal Benefit Endorsement,   
              incorporated by reference to Registrant's Post-Effective
                  Amendment No. 12 filed on July 22, 2004 (File Nos. 333-70384
and 811-08401).                           

hh.                Specimen of Guaranteed Minimum Withdrawal Benefit            
            Endorsement, incorporated by reference to Registrant's
                  Post-Effective Amendment No. 12 filed on July 22, 2004 (File
Nos. 333-70384 and 811-08401).            

ii.                Specimen of 5% for Life Guaranteed Minimum Withdrawal Benefit
            Endorsement, incorporated by reference to Registrant's
                  Post-Effective Amendment No. 12 filed on July 22, 2004 (File
Nos. 333-70384 and 811-08401).            

jj.                Specimen of Guaranteed Minimum Income Benefit Endorsement,   
              incorporated by reference to Registrant's Post-Effective
                  Amendment No. 12 filed on July 22, 2004 (File Nos. 333-70384
and 811-08401).                           

kk.                Specimen of 4% for Life Guaranteed Minimum Withdrawal Benefit
            Endorsement, incorporated by reference to Registrant's
                  Post-Effective Amendment No. 12 filed on July 22, 2004 (File
Nos. 333-70384 and 811-08401).            

ll.                Specimen of 3 Year Withdrawal Charge Schedule Endorsement,   
              incorporated by reference to Registrant's Post-Effective
                  Amendment No. 12 filed on July 22, 2004 (File Nos. 333-70384
and 811-08401).                           

mm.                Specimen of 5 Year Withdrawal Charge Schedule Endorsement,   
              incorporated by reference to Registrant's Post-Effective
                  Amendment No. 12 filed on July 22, 2004 (File Nos. 333-70384
and 811-08401).                           

nn.                Specimen of Highest Anniversary Value Death Benefit          
            Endorsement, incorporated by reference to Registrant's
                  Post-Effective Amendment No. 12 filed on July 22, 2004 (File
Nos. 333-70384 and 811-08401).            

oo.                Specimen of Tax Sheltered Annuity Endorsement, incorporated  
                  by reference to Registrant's Registration Statement filed on
           August 19, 2004 (File Nos. 333-118370 and 811-08401).

pp.                Specimen of Retirement Plan Endorsement, incorporated by     
               reference to Registrant's Registration Statement filed on
           August 19, 2004 (File Nos. 333-118370 and 811-08401).

qq.                Specimen of Individual Retirement Annuity Endorsement,       
            incorporated by reference to Registrant's Registration
                  Statement filed on August 19, 2004 (File Nos. 333-118370 and
811-08401).                               

rr.                Specimen of Roth IRA Endorsement, incorporated by reference  
                to Registrant's Registration Statement filed on August 19,
2004 (File Nos. 333-118370 and 811-08401).

ss.                Specimen of Charitable Remainder Trust Endorsement,          
             incorporated by reference to Registrant's Pre-Effective
                Amendment filed on December 30, 2004 (File Nos. 333-119659
and 811-08401).                           

tt.                Specimen of 5% for Life Guaranteed Minimum Withdrawal Benefit
            Endorsement, incorporated by reference to Registrant's
                Registration Statement filed on January 6, 2005 (File Nos.
333-121884 and811-08401).                 

uu.                Specimen of Guaranteed Minimum Income Benefit Endorsement,   
            incorporated by reference to Registrant's Registration
                  Statement filed on October 4, 2004 (File Nos. 333-119522 and
811-08401).                               

vv.                Specimen of Guaranteed Minimum Withdrawal Benefit            
            Endorsement, incorporated by reference to Registrant's
                Registration Statement filed on January 6, 2005 (File Nos.
333-121884 and 811-08401).                

ww.                Specimen of Guaranteed Minimum Withdrawal Benefit            
            Endorsement, incorporated by reference to Registrant's
                Post-Effective Amendment No. 15 filed on February 14, 2005
(File Nos. 333-70384 and 811-08401).      

xx.                Specimen of 2% Contract Enhancement Endorsement, incorporated
                  by reference to Registrant's Post-Effective Amendment No. 17
                  filed on April 27, 2005 (File Nos. 333-70384 and 811-08401).

yy.                Specimen of 3% Contract Enhancement Endorsement, incorporated
                  by reference to Registrant's Post-Effective Amendment No. 17
                  filed on April 27, 2005 (File Nos. 333-70384 and 811-08401).

zz.                Specimen of 5% for Life Guaranteed Minimum Withdrawal Benefit
            Endorsement, incorporated by reference to Registrant's
                   Post-Effective Amendment No. 17 filed on April 27, 2005 (File
Nos. 333-70384 and 811-08401).            

aaa.               Specimen of 5% Guaranteed Minimum Withdrawal Benefit With    
              Annual Step-up Endorsement, incorporated by reference to
                Registrant's Post-Effective Amendment No. 18 filed on June
   20, 2005 (File Nos. 333-70384 and 811-08401).

bbb.               Specimen of 5% Guaranteed Minimum Withdrawal Benefit         
            Endorsement, incorporated by reference to Registrant's
                  Post-Effective Amendment No. 18 filed on June 20, 2005 (File
Nos. 333-70384 and 811-08401).            

ccc.               Specimen of Guaranteed Minimum Income Benefit Endorsement,   
              incorporated by reference to Registrant's Post-Effective
           Amendment No. 20 filed on October 20, 2005 (File Nos.
333-70384 and 811-08401).                 

ddd.               Specimen of 5% for Life Guaranteed Minimum Withdrawal Benefit
            Endorsement, incorporated by reference to Registrant's
               Post-Effective Amendment No. 20 filed on October 20, 2005
(File Nos. 333-70384 and 811-08401).      

eee.               Specimen of 4% for Life Guaranteed Minimum Withdrawal Benefit
            Endorsement, incorporated by reference to Registrant's
               Post-Effective Amendment No. 20 filed on October 20, 2005
(File Nos. 333-70384 and 811-08401).      

fff.               Specimen of Guaranteed Minimum Withdrawal Benefit            
            Endorsement, incorporated by reference to Registrant's
               Post-Effective Amendment No. 20 filed on October 20, 2005
(File Nos. 333-70384 and 811-08401).      

ggg.               Specimen of 5% for Life Guaranteed Minimum Withdrawal Benefit
                   With Annual Step-Up Endorsement, incorporated by reference to
           Registrant's Post-Effective Amendment No. 23 filed on
          April 27, 2006 (Files Nos. 333-70384 and 811-08401).

hhh.               Specimen of 5% for Life Guaranteed Minimum Withdrawal Benefit
                With Bonus and Annual Step-Up Endorsement, incorporated by
               reference to Registrant's Post-Effective Amendment No. 23
                   filed on April 27, 2006 (Files Nos. 333-70384 and 811-08401).

iii.               Specimen of 5% for Life Guaranteed Minimum Withdrawal Benefit
                   With Bonus and Five Year Step-Up Endorsement, incorporated by
               reference to Registrant's Post-Effective Amendment No. 23
                   filed on April 27, 2006 (Files Nos. 333-70384 and 811-08401).

jjj.               Specimen of Joint 5% for Life Guaranteed Minimum Withdrawal  
              Benefit With Annual Step-Up Endorsement, incorporated by
               reference to Registrant's Post-Effective Amendment No. 23
                   filed on April 27, 2006 (Files Nos. 333-70384 and 811-08401).

kkk.               Specimen of Joint 5% for Life Guaranteed Minimum Withdrawal  
           Benefit With Bonus and Five Year Step-Up Endorsement,
              incorporated by reference to Registrant's Post-Effective
          Amendment No. 23 filed on April 27, 2006 (Files Nos.
333-70384 and 811-08401).                 

lll.               Specimen of Joint 5% for Life Guaranteed Minimum             
        Withdrawal Benefit With Annual Step-Up Endorsement
            incorporated by reference to Registrant's Registration
      Statement filed on September 20, 2006 (File Nos.
333-136485 and 811-08401).                

mmm.               Specimen of Joint 5% for Life Guaranteed Minimum Withdrawal  
           Benefit With Bonus and Five Year Step-Up Endorsement,
attached hereto.                          

5.a.               Form of the Perspective II Fixed and Variable Annuity        
            Application, incorporated by reference to Registrant's
              Pre-Effective Amendment No. 1 filed on December 19, 2001
(333-70384 and 811-08401).                

b.                 Form of the Perspective II Fixed and Variable Annuity        
            Application, incorporated by reference to Registrant's
                  Post-Effective Amendment No. 5 filed on April 30, 2003 (File
Nos. 333-70384 and 811-08401).            

c.                 Form of the Perspective II Fixed and Variable Annuity        
            Application, incorporated by reference to Registrant's
                 Post-Effective Amendment No. 6 filed on June 20, 2003 (File
Nos. 333-70384 and 811-08401).            

d.                 Form of the Perspective II Fixed and Variable Annuity        
            Application, incorporated by reference to Registrant's
                   Post-Effective Amendment No. 11 filed on April 29, 2004 (File
Nos. 333-70384 and 811-08401).            

e.                 Form of the Perspective II Fixed and Variable Annuity        
            Application, incorporated by reference to Registrant's
                  Post-Effective Amendment No. 12 filed on July 22, 2004 (File
Nos. 333-70384 and 811-08401).            

g.                 Form of the Perspective II Fixed and Variable Annuity        
            Application, incorporated by reference to Registrant's
                Post-Effective Amendment No. 15 filed on February 14, 2005
(File Nos. 333-70384 and 811-08401).      

h.                 Form of the Perspective II Fixed and Variable Annuity        
            Application, incorporated by reference to Registrant's
                Post-Effective Amendment No. 19 filed on September 2, 2005
(File Nos. 333-70384 and 811-08401).      

i.                 Form of the Perspective II Fixed and Variable Annuity        
Application, attached hereto.             

6.a.               Declaration and Charter of Depositor, incorporated by        
               reference to Registrant's Registration Statement filed on
          October 3, 1997 (File Nos. 333-37175 and 811-08401).

b.                 By-laws of Depositor, incorporated by reference to           
                  Registrant's Registration Statement filed on October 3, 1997
(File Nos. 333-37175 and 811-08401).      

7.a.               Variable Annuity GMIB Reinsurance Agreement, incorporated by 
                   reference to the Registrant's Post-Effective Amendment No. 12
         filed on December 15, 2004 (File Nos. 333-37175 and
811-08401).                               

b.                 Amendment No. 2 to the Variable Annuity GMIB Reinsurance     
                Agreement, incorporated by reference to Registrant's Post-
                  Effective Amendment No. 12 filed on July 22, 2004 (File Nos.
333-70384 and 811-08401).                 

c.                 Variable Annuity GMIB Reinsurance Agreement, incorporated by 
               reference to Registrant's Post-Effective Amendment No. 20
        filed on October 20, 2005 (File Nos. 333-70384 and
811-08401).                               

d.                 Amendments to the January 1, 2003 Variable Annuity GMIB      
Reinsurance Agreement, attached hereto.   

8.                 Not Applicable                                               

9.                 Opinion and Consent of Counsel, attached hereto.             

10.                Consent of Independent Registered Public Accounting Firm,    
attached hereto.                          

11.                Not Applicable                                               

12.                Not Applicable                                               

Item 25. Directors and Officers of the Depositor                                

                                                        [Enlarge/Download Table]

                                                                                                                      

Name and Principal Business Address               Positions and Offices with Depositor                                

Donald B. Henderson, Jr.                          Director                                                            
4A Rivermere Apartments                                                                                               
Bronxville, NY 10708                                                                                                  

David L. Porteous                                 Director                                                            
20434 Crestview Drive                                                                                                 
Reed City, MI 49777                                                                                                   

Donald T. DeCarlo                                 Director                                                            
200 Manor Road                                                                                                        
Douglaston, New York 11363                                                                                            

Joanne P. McCallie                                Director                                                            
1 Birch Road                                                                                                          
110 Berkowitz                                                                                                         
East Lansing, MI 48824                                                                                                

Gary H. Torgow                                    Director                                                            
220 West Congress                                                                                                     
Detroit, MI 48226-3213                                                                                                

Richard D. Ash                                    Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

John B. Banez                                     Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

James P. Binder                                   Vice President & Treasurer                                          
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

John H. Brown                                     Vice President & Director                                           
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Joseph Mark Clark                                 Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Marianne Clone                                    Vice President & Director                                           
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

James B. Croom                                    Vice President & Deputy General Counsel                             
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Lisa C. Drake                                     Senior Vice President                                               
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Phillip Brian Eaves                               Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Robert A. Fritts                                  Senior Vice President & Controller                                  
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

James D. Garrison                                 Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Julia A. Goatley                                  Vice President, Senior Counsel, Assistant Secretary & Director      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

James G. Golembiewski                             Vice President & Chief of Compliance for Separate Accounts          
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Andrew B. Hopping                                 Executive Vice President, Chief Financial Officer &                 
1 Corporate Way                                   Chairman of the Board                                               
Lansing, MI 48951                                                                                                     

Stephen A. Hrapkiewicz, Jr.                       Senior Vice President                                               
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Clifford J. Jack                                  Executive Vice President & Chief Distribution Officer               
8055 E. Tufts Avenue                                                                                                  
Suite 1000                                                                                                            
Denver, CO 80237                                                                                                      

Timo P. Kokko                                     Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Everett W. Kunzelman                              Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Clark P. Manning, Jr.                             President & Chief Executive Officer                                 
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Herbert G. May III                                Chief Administrative Officer & Director                             
275 Grove St Building 2                                                                                               
4th floor                                                                                                             
Auburndale, MA 02466                                                                                                  

Thomas J. Meyer                                   Senior Vice President, General Counsel, Secretary & Director        
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Keith R. Moore                                    Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

P. Chad Myers                                     Senior Vice President                                               
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

J. George Napoles                                 Executive Vice President & Chief Information Officer                
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Mark D. Nerud                                     Vice President                                                      
225 W. Wacker Drive                                                                                                   
Suite 1200                                                                                                            
Chicago, IL 60606                                                                                                     

Russell E. Peck                                   Vice President & Director                                           
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Laura L. Prieskorn                                Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

James B. Quinn                                    Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Greg B. Salsbury                                  Vice President & Director                                           
8055 E. Tufts Avenue                                                                                                  
Suite 1100                                                                                                            
Denver, CO 80237                                                                                                      

Kathleen M. Smith                                 Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

James R. Sopha                                    Executive Vice President                                            
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Heather R. Strang                                 Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Robert M. Tucker, Jr.                             Vice President                                                      
1 Corporate Way                                                                                                       
Lansing, MI 48951                                                                                                     

Michael A. Wells                                  Chief Operating Officer                                             
401 Wilshire Blvd.                                                                                                    
Suite 1200                                                                                                            
Santa Monica, CA 90401                                                                                                

Item 26.   Persons Controlled by or Under Common Control with the Depositor or Registrant.                            

Company                         State of Organization         Control/Ownership             Business Principal        

120 Orion, LLC                  South Carolina                100% Jackson National Life    Real Estate               
                                                              Insurance Company                                       

Alcona Funding LLC              Delaware                      100% Jackson National Life    Investment Related Company
                                                              Insurance Company                                       

Berrien Funding LLC             Delaware                      100% Jackson National Life    Investment Related Company
                                                              Insurance Company                                       

BH Clearing, LLC                Michigan                      100% Jackson National Life    Broker/Dealer             
                                                              Insurance Company                                       

Brook GP                        Delaware                      100% Brook (Holdco 2) Inc.    Holding Company Activities

Brooke LLC                      Delaware                      100% Prudential Four Limited  Holding Company Activities

Brook (Holdco 1) Inc.           Delaware                      100% Prudential (US           Holding Company Activities
                                                              Holdco3) BV                                             

Brook (Holdco 2) Inc.           Delaware                      100% Brook (Holdco 1) Inc.    Holding Company Activities

Brooke Holdings, LLC            Delaware                      100% Brooke Holdings (UK)     Holding Company Activities
                                                              Limited                                                 

Brooke Holdings (UK) Limited    United Kingdom                100% Holborn Delaware         Holding Company Activities
                                                              Corporation                                             

Brooke Investment, Inc.         Delaware                      100% Brooke Holdings, Inc.    Investment Related Company

Brooke Life Insurance Company   Michigan                      100% Brooke Holdings, Inc.    Life Insurance            

Brooke (Jersey) Limited         United Kingdom                100% Prudential One Limited   Holding Company Activities

Calhoun Funding LLC             Delaware                      100% Jackson National Life    Investment Related Company
                                                              Insurance Company                                       

Crescent Telephone              Delaware                      100% Jackson National Life    Telecommunications        
                                                              Insurance Company                                       

Curian Capital, LLC             Michigan                      100% Jackson National Life    Registered Investment     
                                                              Insurance Company             Advisor                   

Equestrian Pointe Investors,    Illinois                      100% Jackson National Life    Real Estate               
L.L.C.                                                        Insurance Company                                       

Forty Partners #1, L.C.         Missouri                      100% Jackson National Life    Real Estate               
                                                              Insurance Company                                       

GCI Holding Corporation         Delaware                      70% Jackson National Life     Holding Company Activities
                                                              Insurance Company                                       

GS28 Limited                    United Kingdom                100% Brooke Holdings (UK)     Holding Company Activities
                                                              Limited                                                 

Hermitage Management, LLC       Michigan                      100% Jackson National Life    Advertising Agency        
                                                              Insurance Company                                       

Holborn Delaware Corporation    Delaware                      100% Prudential Four Limited  Holding Company Activities

Holliston Mills                 Delaware                      70% Jackson National Life     Textile Mfg.              
                                                              Insurance Company                                       

Industrial Coatings Group       Delaware                      70% Jackson National Life     Textile Mfg.              
                                                              Insurance Company                                       

IFC Holdings, Inc.              Delaware                      100% National Planning        Broker/Dealer             
                                                              Holdings Inc.                                           

Investment Centers of America   Delaware                      100% IFC Holdings, Inc.       Broker/Dealer             

JNL Investors Series Trust      Massachusetts                 100% Jackson National Life    Investment Company        
                                                              Insurance Company                                       

Jackson National Asset          Michigan                      100% Jackson National Life    Investment Adviser and    
Management, LLC                                               Insurance Company             Transfer Agent            

Jackson National Life           Bermuda                       100% Jackson National Life    Life Insurance            
(Bermuda) Ltd.                                                Insurance Company                                       

Jackson National Life           Delaware                      100% Jackson National Life    Advertising/Marketing     
Distributors, Inc.                                            Insurance Company             Corporation and           
                                                                                            Broker/Dealer             

Jackson National Life           New York                      100% Jackson National Life    Life Insurance            
Insurance Company                                             Insurance Company of New                                
                                                              York                                                    

JNLI LLC                        Delaware                      100% Jackson National Life    Tuscany Notes             
                                                              Insurance Company                                       

JNL Series Trust                Massachusetts                 Common Law Trust with         Investment Company        
                                                              contractual association                                 
                                                              with Jackson National Life                              
                                                              Insurance Company of New                                
                                                              York                                                    

JNL Southeast Agency LLC        Michigan                      100% Jackson National Life    Insurance Agency          
                                                              Insurance Company                                       

JNL Variable Fund LLC           Delaware                      100% Jackson National         Investment Company        
                                                              Separate Account - I                                    

JNLNY Variable Fund I LLC       Delaware                      100% JNLNY Separate Account   Investment Company        
                                                              I                                                       

LePages Management Company, LP  Delaware                      50% LePages MC, LLC                                     

LePages MC, LLC                 Delaware                      100% PPM Management, Inc.                               

Life of Georgia Agency, Inc.    Georgia                       100% Brooke Holdings, Inc.    Insurance Agency          

Meadows NRH Associates, L.P.    Texas                         100% Meadows NRH, Inc.        Real Estate               

Meadows NRH, Inc.               Texas                         100% Jackson National Life    Real Estate               
                                                              Insurance Company                                       

National Planning Corporation   Delaware                      100% National Planning        Broker/Dealer and         
                                                              Holdings, Inc.                Investment Adviser        

National Planning Holdings,     Delaware                      100% Brooke Holdings, Inc.    Holding Company Activities
Inc.                                                                                                                  

Nicole Finance Inc.             Delaware                      100% Brooke GP                Holding Company Activities

Piedmont Funding LLC            Delaware                      100% Jackson National Life    Investment Related Company
                                                              Insurance Company                                       

PPM Holdings, Inc.              Delaware                      100% Brooke Holdings, Inc.    Holding Company Activities

Prudential plc                  United Kingdom                Publicly Traded               Financial Institution     

Prudential Corporation          United Kingdom                100% Prudential Holdings      Holding Company Activities
Holdings, Limited                                             Limited                                                 

Prudential Holdings Limited     Scotland                      100% Prudential plc           Holding Company Activities

Prudential One Limited          United Kingdom                100% Prudential plc           Holding Company Activities

Item 27. Number of Contract Owners as of October 20, 2006                       

Qualified - 6,466                                                     
Non-qualified - 5,380                                                 

Item 28. Indemnification                                                        

Provision is made in the Company's By-Laws for indemnification by the Company of
any person made or threatened to be made a party to an action or proceeding,    
whether civil or criminal by reason of the fact that he or she is or was a      
director, officer or employee of the Company or then serves or has served any   
other corporation in any capacity at the request of the Company, against        
expenses, judgments, fines and amounts paid in settlement to the full extent    
that officers and directors are permitted to be indemnified by the laws of the  
State of New York.                                                              

Insofar as indemnification for liabilities arising under the Securities Act of  
1933 ("Act") may be permitted to directors, officers and controlling persons of 
the Company pursuant to the foregoing provisions, or otherwise, the Company has 
been advised that in the opinion of the Securities and Exchange Commission such 
indemnification is against public policy as expressed in the Act and is,        
therefore, unenforceable. In the event that a claim for indemnification against 
liabilities (other than the payment by the Company of expenses incurred or paid 
by a director, officer or controlling person of the Company in the successful   
defense of any action, suit or proceeding) is asserted by such director, officer
or controlling person in connection with the securities being registered, the   
Company will, unless in the opinion of its counsel the matter has been settled  
by controlling precedent, submit to a court of appropriate jurisdiction the     
question whether such indemnification by it is against public policy as         
expressed in the Act and will be governed by the final adjudication of such     
issue.                                                                          

Item 29. Principal Underwriter                                                  

 (a)    Jackson National Life Distributors, Inc. acts as general
              distributor for the JNLNY Separate Account I. Jackson National
                Life Distributors, Inc. also acts as general distributor for the
           Jackson National Separate Account - I, the Jackson National
               Separate Account III, the Jackson National Separate Account IV,
           the Jackson National Separate Account V, the JNLNY Separate
Account II, and the JNLNY Separate Account IV.  

      (b)    Directors and Officers of Jackson National Life Distributors,
Inc.:                                           

                                                        [Enlarge/Download Table]

                                                                                                   

Name and Business Address                           Positions and Offices with Underwriter         

Michael A. Wells                                    Director                                       
401 Wilshire Blvd.                                                                                 
Suite 1200                                                                                         
Santa Monica, CA 90401                                                                             

Andrew B. Hopping                                   Chief Financial Officer                        
1 Corporate Way                                                                                    
Lansing, MI 48951                                                                                  

Clifford J. Jack                                    Director, President and Chief Executive Officer
8055 E. Tufts Avenue                                                                               
Suite 1000                                                                                         
Denver, CO 80237                                                                                   

Nikhil Advani                                       Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Stephen M. Ash                                      Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Pamela Aurbach                                      Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Brad Baker                                          Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Linda Baker                                         Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Janice Blanchard                                    Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

William Britt                                       Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Tori Bullen                                         Senior Vice President                          
210 Interstate North Parkway                                                                       
Suite 401                                                                                          
Atlanta, GA 30339-2120                                                                             

Greg Cicotte                                        Executive Vice President                       
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Maura Collins                                       Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Robert DiNardo                                      Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Paul Fitzgerald                                     Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Julia A. Goatley                                    Assistant Secretary                            
1 Corporate Way                                                                                    
Lansing, MI 48951                                                                                  

Luis Gomez                                          Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Kevin Grant                                         Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Bonnie Howe                                         Vice President and Deputy General Counsel      
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Thomas Hurley                                       Senior Vice President                          
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Mark Jones                                          Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Steve Kluever                                       Senior Vice President                          
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Brian Lane                                          Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

James Livingston                                    Executive Vice President                       
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Doug Mantelli                                       Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Susan McClure                                       Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

James McCorkle                                      Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Brook Meyer                                         Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Thomas J. Meyer                                     Director and Secretary                         
1 Corporate Way                                                                                    
Lansing, MI 48951                                                                                  

Jack Mishler                                        Senior Vice President                          
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Justin Rafferty                                     Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Peter Radloff                                       Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Gregory B. Salsbury                                 Executive Vice President                       
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Kathleen Schofield                                  Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Greg Smith                                          Senior Vice President                          
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Sam Somuri                                          Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

David Sprague                                       Senior Vice President                          
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Daniel Starishevsky                                 Senior Vice President                          
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Doug Townsend                                       Vice President and Controller and FinOp        
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

C. Ray Trueblood                                    Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Daniel Wright                                       Vice President and Chief Compliance Officer    
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

Phil Wright                                         Vice President                                 
8055 E. Tufts Avenue                                                                               
Suite 1100                                                                                         
Denver, CO 80237                                                                                   

         (c)                                                                                       

Name of Principal       Net Underwriting  Compensation on      Brokerage             Compensation  
Underwriter             Discounts and     Redemption or        Commissions                         
                        Commissions       Annuitization                                            

Jackson National Life   Not Applicable    Not Applicable       Not Applicable        Not Applicable
Distributors, Inc.                                                                                 

Item 30. Location of Accounts and Records                                       

Jackson National Life Insurance Company                   
1 Corporate Way                                           
Lansing, Michigan 48951                                   

Jackson National Life Insurance Company                   
Institutional Marketing Group Service Center              
1 Corporate Way                                           
Lansing, Michigan 48951                                   

Jackson National Life Insurance Company                   
8055 East Tufts Ave., Second Floor                        
Denver, Colorado 80237                                    

Jackson National Life Insurance Company                   
225 West Wacker Drive, Suite 1200                         
Chicago, IL  60606                                        

Item 31. Management Services                                                    

Not Applicable                                            

Item 32. Undertakings and Representations                                       

a.   Jackson National Life Insurance Company of New York hereby undertakes to   
file a post-effective amendment to this registration statement as     
    frequently as is necessary to ensure that the audited financial statements
   in the registration statement are never more than sixteen (16) months old
for so long as payment under the variable annuity contracts may be    
accepted.                                                             

b.   Jackson National Life Insurance Company of New York hereby undertakes to   
include either (1) as part of any application to purchase a contract  
     offered by the Prospectus, a space that an applicant can check to request a
   Statement of Additional Information, or (2) a postcard or similar written
   communication affixed to or included in the Prospectus that the applicant
can remove to send for a Statement of Additional Information.         

c.   Jackson National Life Insurance Company of New York hereby undertakes to   
     deliver any Statement of Additional Information and any financial statement
     required to be made available under this Form promptly upon written or oral
request.                                                              

d.   Jackson National Life Insurance Company of New York represents that the    
fees and charges deducted under the contract, in the aggregate, are   
reasonable in relation to the services rendered, the expenses to be   
    incurred, and the risks assumed by Jackson National Life Insurance Company
of New York.                                                          

e.   The Registrant hereby represents that any contract offered by the          
   prospectus and which is issued pursuant to Section 403(b) of the Internal
   Revenue Code of 1986, as amended, is issued by the Registrant in reliance
upon, and in compliance with, the Securities and Exchange Commission's
  industry-wide no-action letter to the American Council of Life Insurance
(publicly available November 28, 1988) which permits withdrawal       
     restrictions to the extent necessary to comply with IRC Section 403(b)(11).

SIGNATURES

     As required by the Securities Act of 1933 and the Investment Company Act of
1940, the Registrant  certifies that it meets the requirements of Securities Act
Rule 485(b) for  effectiveness of this  Post-Effective  Amendment and has caused
this  Post-Effective  Amendment  to be  signed  on its  behalf,  in the  City of
Lansing, and State of Michigan, on this 21st day of December, 2006.             

JNLNY Separate Account I                                                        
(Registrant)                                                                    

Jackson National Life Insurance Company of New York                             

By:  THOMAS J. MEYER                                                            
-----------------------                                                 
Thomas J. Meyer                                                       
Senior Vice President, General Counsel,                               
Secretary and Director                                                

Jackson National Life Insurance Company of New York (Depositor)                 

By:  THOMAS J. MEYER                                                            
-----------------------                                                 
Thomas J. Meyer                                                       
Senior Vice President, General Counsel,                               
Secretary and Director                                                

     As required by the Securities Act of 1933, this post-effective amendment to
the  Registration  Statement  has been  signed by the  following  persons in the
capacities and on the dates indicated.                                          

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
Clark P. Manning, Jr.                                         Date              
President and Chief Executive Officer                                           

THOMAS J. MEYER*                                              December 21, 2006 
------------------                                           -----------------  
Andrew B. Hopping                                             Date              
Executive Vice President, Chief Financial Officer, and                          
Director                                                                        

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
Herbert G. May III                                            Date              
Chief Administrative Officer and Director                                       

THOMAS J. MEYER                                               December 21, 2006 
-------------------                                           ----------------- 
Thomas J. Meyer                                               Date              
Senior Vice President, General Counsel  and Director                            

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
John J. Brown                                                 Date              
Vice President - Government Relations and Director                              

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
Marianne Clone                                                Date              
Vice President - Administration -Customer Service Center                        
and Director                                                                    

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
Julia A. Goatley                                              Date              
Vice President, Senior Counsel, Assistant Secretary and                         
Director                                                                        

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
Russell E. Peck                                               Date              
Vice President - Financial Operations and Director                              

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
Donald B. Henderson, Jr.                                      Date              
Director                                                                        

THOMAS J. MEYER*                                              December 21, 2006 
------------------                                           -----------------  
David C. Porteous                                             Date              
Director                                                                        

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
Donald T. DeCarlo                                             Date              
Director                                                                        

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
Joanne P. McCallie                                            Date              
Director                                                                        

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
Gary H. Torgow                                                Date              
Director                                                                        

THOMAS J. MEYER*                                              December 21, 2006 
-------------------                                           ----------------- 
Gregory B. Salsbury                                           Date              
Director                                                                        

* Thomas J. Meyer, Attorney In Fact                                             

 POWER OF ATTORNEY

   KNOW ALL MEN BY THESE  PRESENTS,  that each of the undersigned as directors
and/or  officers of JACKSON  NATIONAL  LIFE  INSURANCE  COMPANY OF NEW YORK (the
Depositor),  a New York  corporation,  hereby  appoints  Clark P. Manning,  Jr.,
Andrew B. Hopping,  Thomas J. Meyer, Patrick W. Garcy, Susan S. Rhee and Anthony
L. Dowling (each with power to act without the others) his/her  attorney-in-fact
and  agent,  with full  power of  substitution  and  resubstitution,  for and in
his/her name, place and stead, in any and all capacities,  to sign  applications
and registration statements, and any and all amendments, with power to affix the
corporate  seal and to attest  it,  and to file the  applications,  registration
statements,  and amendments,  with all exhibits and requirements,  in accordance
with the Securities Act of 1933, the Securities and Exchange Act of 1934, and/or
the  Investment  Company  Act of 1940.  This Power of  Attorney  concerns  JNLNY
Separate  Account I (333-37175,  333-48822,  333-70384,  333-81266,  333-118370,
333-119659 and  333-136485),  JNLNY Separate  Account II (333-86933),  and JNLNY
Separate Account IV (333-109762 and 333-118132),  as well as any future separate
accounts  the  Depositor  establishes  through  which  securities,  particularly
variable annuity contracts and variable universal life insurance  policies,  are
to be offered for sale. The undersigned grant to each attorney-in-fact and agent
full  authority to take all necessary  actions to effectuate the above as fully,
to all intents and purposes, as he/she could do in person, thereby ratifying and
confirming  all that said  attorneys-in-fact  and  agents,  or any of them,  may
lawfully  do or  cause  to be done by  virtue  hereof.  This  instrument  may be
executed in one or more counterparts.                                           

     IN WITNESS WHEREOF, the undersigned have executed this Power of Attorney as
of the 18th day of October, 2006.                                               

CLARK P. MANNING, JR                                                            
----------------------------------------------                                  
Clark P. Manning, Jr.                                                           
President and Chief Executive Officer                                           

ANDREW B. HOPPING                                                               
----------------------------------------------                                  
Andrew B. Hopping                                                               
Executive Vice President, Chief Financial Officer                               
and Director                                                                    

HERBERT G. MAY III                                                              
----------------------------------------------                                  
Herbert G. May III                                                              
Chief Administrative Officer and Director                                       

THOMAS J. MEYER                                                                 
----------------------------------------------                                  
Thomas J. Meyer                                                                 
Senior Vice President, General Counsel and Director                             

JOHN H. BROWN                                                                   
----------------------------------------------                                  
John H. Brown                                                                   
Vice President and Director                                                     

485BPOS
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MARIANNE CLONE                                                                  
----------------------------------------------                                  
Marianne Clone                                                                  
Vice President and Director                                                     

JULIA A. GOATLEY                                                                
----------------------------------------------                                  
Julia A. Goatley                                                                
Vice President, Senior Counsel, Assistant Secretary                             
and Director                                                                    

RUSSELL E. PECK                                                                 
----------------------------------------------                                  
Russell E. Peck                                                                 
Vice President and Director                                                     

DONALD B. HENDERSON, JR.                                                        
----------------------------------------------                                  
Donald B. Henderson, Jr.                                                        
Director                                                                        

DAVID L. PORTEOUS                                                               
----------------------------------------------                                  
David L. Porteous                                                               
Director                                                                        

DONALD T. DECARLO                                                               
----------------------------------------------                                  
Donald T. DeCarlo                                                               
Director                                                                        

JOANNE P. MCCALLIE                                                              
----------------------------------------------                                  
Joanne P. McCallie                                                              
Director                                                                        

GARY H. TORGOW                                                                  
----------------------------------------------                                  
Gary H. Torgow                                                                  
Director                                                                        

GREGORY B. SALSBURY                                                             
----------------------------------------------                                  
Gregory B. Salsbury                                                             
Vice President and Director                                                     

EXHIBIT LIST

Exhibit No.        Description                                                  

4.mmm.             Specimen of Joint 5% for Life Guaranteed Minimum Withdrawal  
           Benefit With Bonus and Five Year Step-Up Endorsement,
attached hereto as EX-4.mmm.              

5.i.               Form of the Perspective II Fixed and Variable Annuity        
Application, attached hereto as EX-5.i.   

7.d.               Amendments to the January 1, 2003 Variable Annuity GMIB      
       Reinsurance Agreement, attached hereto as EX-7.d.

9.                 Opinion and Consent of Counsel, attached hereto as EX-9.     

10.                Consent of Independent Registered Public Accounting Firm,    
attached hereto as EX-10.                 

Dates Referenced Herein   and   Documents Incorporated by Reference

				Referenced-On Page
This ‘485BPOS’ Filing		Date		First		Last			Other Filings
		1/16/07		2		3
Effective on:		12/22/06		1		3			485BPOS
Filed on:		12/21/06		1		4			485BPOS
		10/20/06		4
		9/20/06		4					N-4
		8/10/06		4
		6/1/06		4
		5/1/06		2		3			485BPOS,  497
		4/27/06		1		4			485BPOS
		12/31/05		4					24F-2NT,  NSAR-U
		12/29/05		4					485BPOS
		10/25/05		4
		10/20/05		4					485APOS
		9/2/05		4					485BPOS
		6/20/05		4					485APOS
		4/27/05		4					485BPOS
		2/14/05		4					485APOS,  497J
		1/6/05		4					N-4
		12/31/04		4					24F-2NT,  NSAR-U
		12/30/04		4					N-4/A
		12/15/04		4
		10/4/04		4					485BPOS,  497,  N-4
		8/19/04		4					N-4
		7/22/04		4					485APOS
		4/29/04		4					485BPOS
		12/31/03		4					24F-2NT,  NSAR-U
		6/20/03		4					485APOS,  485BPOS,  AW
		4/30/03		4					485BPOS
		1/1/03		4		5
		11/1/02		4					485APOS
		5/20/02		4					485APOS
		5/17/02		4					485BPOS
		12/19/01		4					N-4/A
		9/28/01		4					N-4
		6/30/98		4
		10/3/97		4					N-4 EL,  N-8A
		9/19/97		4
									List all Filings

8 Subsequent Filings that Reference this Filing

  As Of               Filer                 Filing    For·On·As Docs:Size             Issuer                      Filing Agent

 4/25/24  Jnlny Separate Account I          485BPOS     4/29/24    3:6.1M
 4/25/24  Jnlny Separate Account I          485BPOS     4/29/24    3:5.7M
 4/27/23  Jnlny Separate Account I          485BPOS     5/01/23    3:5.9M
 4/27/23  Jnlny Separate Account I          485BPOS     5/01/23    3:5.7M
 4/21/22  Jnlny Separate Account I          485BPOS     4/25/22    3:6M
 4/21/22  Jnlny Separate Account I          485BPOS     4/25/22    3:5.8M
 4/22/21  Jnlny Separate Account I          485BPOS     4/26/21    3:27M
 4/21/21  Jnlny Separate Account I          485BPOS     4/26/21    3:68M