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Participation Agreement

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Date:
2002
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53K
ID:
#142659

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                             PARTICIPATION AGREEMENT


      THIS  AGREEMENT,  made and entered into this __ day of February,  2002, by
and between MFS FUND DISTRIBUTORS, INC., a Delaware corporation ("MFS"), and AIG
Life Insurance  Company,  a Delaware  corporation  (the  "Company"),  on its own
behalf and on behalf of each of the  segregated  asset  accounts  of the Company
listed in Schedule B (the "Account" or the "Accounts");

      WHEREAS, each of the funds which comprise the MFS Family of Funds (certain
of which may from time to time be listed on Schedule A attached hereto) (each, a
"Fund" and  collectively,  the "Funds") is registered as an open-end  investment
company under the Investment Company Act of 1940 as amended (the "1940 Act"),

      WHEREAS each Fund is comprised of multiple  classes of shares which are or
will be registered under the Securities Act of 1933 as amended (the "1933 Act");

      WHEREAS MFS is  registered  as a  broker-dealer  with the  Securities  and
Exchange  Commission  (the "SEC") under the Securities  Exchange Act of 1934, as
amended  (hereinafter  the "1934 Act"),  and is a member in good standing of the
National Association of Securities Dealers, Inc. (the "NASD");

      WHEREAS,  MFS serves as distributor  for each of the Funds pursuant to the
terms of a Distribution Agreement between each of the Funds and MFS;

      WHEREAS,  the Company will issue certain group fixed and variable  annuity
contracts (individually, the "Policy" or collectively, the "Policies") which, if
required, will be registered under the 1933 Act;

      WHEREAS,  the Accounts are duly  organized,  validly  existing  segregated
asset  accounts,  established  by  resolution  of the Board of  Directors of the
Company,  to set aside and invest assets  attributable  to the  aforesaid  group
fixed and/or variable annuity  contracts that are allocated to the Accounts (the
Policies and the Accounts covered by this Agreement, and each corresponding Fund
covered by this Agreement in which the Accounts invest, is specified in Schedule
A attached hereto as may be modified from time to time);

      WHEREAS,  to  the  extent  permitted  by  applicable  insurance  laws  and
regulations,  the Company  intends to purchase  Class A shares in one or more of
the Funds  specified in Schedule A attached  hereto (the  "Shares") on behalf of
the  Accounts to fund the  Policies,  and MFS intends to sell such Shares to the
Accounts;

      NOW,  THEREFORE,  in consideration  of their mutual promises,  MFS and the
Company agree as follows:

ARTICLE I.  Sale of Trust Shares

      1.1.  MFS agrees to sell to the Company  those  Shares  which the Accounts
      order (based on orders  placed by Policy  holders on that Business Day, as
      defined  below) and which are  available  for  purchase by such  Accounts,
      executing  such  orders  on a daily  basis  at the net  asset  value  next
      computed after receipt by MFS or its designee of the order for the Shares.
      For purposes of this Section 1.1, the Company shall be the designee of MFS
      for receipt of such orders from Policy owners and receipt by such designee
      shall constitute receipt by MFS; provided that MFS receives notice of such
      orders by 9:00  a.m.  Eastern  Time on the next  following  Business  Day.
      "Business  Day" shall  mean any day on which the New York Stock  Exchange,
      Inc.  (the  "NYSE") is open for trading  and on which the Funds  calculate
      their respective net asset values pursuant to the rules of the SEC.

      1.2. MFS agrees to make the Shares available  indefinitely for purchase at
      the  applicable  net asset value per share by the Company and the Accounts
      on those days on which the Funds calculate their respective net



      asset  value  pursuant  to rules of the SEC and each Fund shall  calculate
      such  net  asset  value on each day  which  the NYSE is open for  trading.
      Notwithstanding  the  foregoing,  MFS may refuse to sell any Shares to the
      Company and the  Accounts,  or suspend or  terminate  the  offering of the
      Shares if such  action is  required  by law or by  regulatory  authorities
      having  jurisdiction or, pursuant to a determination  made by the Board of
      Trustees  of any Fund  acting in good faith and in light of its  fiduciary
      duties under federal and any  applicable  state laws,  that such action is
      necessary in the best interest of the Shareholders of such Fund.

      1.3. MFS agrees to redeem for cash, on the Company's request,  any full or
      fractional  Shares held by the Accounts  (based on orders placed by Policy
      holders on that Business Day), executing such requests on a daily basis at
      the net asset value next computed  after receipt by MFS or its designee of
      the request for redemption.  For purposes of this Section 1.3, the Company
      shall be the designee of MFS for receipt of requests for  redemption  from
      Policy owners and receipt by such  designee  shall  constitute  receipt by
      MFS;  provided that MFS receives  notice of such request for redemption by
      9:00 a.m. Eastern Time on the next following Business Day.

      1.4. Each  purchase,  redemption  and exchange order placed by the Company
      shall be placed  separately  for each  Fund and  shall not be netted  with
      respect to any Fund.  However,  with  respect  to payment of the  purchase
      price by the Company and of  redemption  proceeds by MFS,  the Company and
      MFS shall net purchase and redemption orders with respect to each Fund and
      shall  transmit  one net payment for all of the Funds in  accordance  with
      Section 1.5 hereof.

      1.5. In the event of net  purchases,  the Company shall pay for the Shares
      by 4:00  p.m.  Eastern  Time on the next  Business  Day  after an order to
      purchase the Shares is made in accordance  with the  provisions of Section
      1.1. hereof. In the event of net redemptions, MFS shall pay the redemption
      proceeds by 4:00 p.m. Eastern Time on the next Business Day after an order
      to redeem the shares is made in accordance  with the provisions of Section
      1.3.  hereof.  All such payments shall be in federal funds  transmitted by
      wire.

      1.6. Issuance and transfer of the Shares will be by book entry only. Stock
      certificates will not be issued to the Company or the Accounts. The Shares
      ordered from MFS will be recorded in an appropriate title for the Accounts
      or the appropriate subaccounts of the Accounts.

      1.7. MFS shall  furnish same day notice (by wire or telephone  followed by
      written  confirmation)  to the Company of any  dividends  or capital  gain
      distributions  payable on the Shares. The Company hereby elects to receive
      all such dividends and  distributions as are payable on a Fund's Shares in
      additional Shares of that Fund. MFS shall notify the Company of the number
      of Shares so issued as payment of such  dividends and  distributions.  The
      Company reserves the right to revoke this election and to receive all such
      dividends and distributions in cash.

      1.8. MFS or its designee shall make the net asset value per share for each
      Fund  available to the Company on each  Business Day as soon as reasonably
      practical  after the net asset value per share is calculated and shall use
      its best efforts to make such net asset value per share  available by 6:30
      p.m.  Eastern  Time. In the event that MFS is unable to meet the 6:30 p.m.
      time stated herein,  it shall provide  additional  time for the Company to
      place orders for the purchase and  redemption of Shares.  Such  additional
      time shall be equal to the additional time which MFS takes to make the net
      asset value available to the Company. If MFS provides materially incorrect
      share net asset value  information,  MFS shall make an  adjustment  to the
      number of shares  purchased  or redeemed  for the  Accounts to reflect the
      correct net asset value per share.  Any material error in the  calculation
      or  reporting  of net asset  value per share,  dividend  or capital  gains
      information shall be reported promptly upon discovery to the Company.

      1.9 The Fund shall transmit to the Company by 8:30 a.m.  Eastern  Standard
      Time on each Business Day a confirmation of any net purchase or redemption
      orders for  shares of the Fund with a trade  date of the second  preceding
      Business Day. However,  on any Business Day that is the first Business Day


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