This Separate Account Fund invests in the Mid Cap Value Fund of Mutual of America Investment Corporation, which seeks capital appreciation and, to a lesser extent, current income. Such Underlying Fund seeks to achieve its objective by investing in value stocks issued by mid-sized market capitalizations believed to be undervalued in the marketplace in relation to factors such as the company's assets, earnings or growth potential. Under normal market conditions at least 85% of the Fund’s total assets are invested in equity securities and at least 80% of the Fund’s total assets are invested in mid cap value stocks.

The Fund invests primarily in value stocks issued by companies with mid-sized market capitalizations that the Adviser believes to be undervalued in the marketplace in relation to factors such as the company’s assets, earnings or growth potential. Companies with mid-sized market capitalizations are those companies with capital in the range of $2.0 billion to $10.0 billion.

An investment in the Fund is subject to the following risks which are described in more detail in the Prospectus.

The performance data shown above represent past performance, which is not a guarantee of future results. Investment returns and unit values will fluctuate so that units, when redeemed, may be worth more or less than their original cost. Investment Fund total return performance currently may be lower or higher than the figures stated above.

The total return performance data are based on a hypothetical investment of $1,000, which is redeemed at the end of the periods shown. The total return figures reflect the reinvestment of investment income and capital gains and losses, and are net of expenses which include a contract fee, an expense risk fee, administrative charges, a distribution expense charge and Underlying Funds fees and expenses. Before investing in our variable accumulation annuity contracts, you should consider the investment objectives, risks, charges and expenses (a contract fee, Separate Account expenses and Underlying Funds expenses) carefully. This and other information is contained in the contract prospectus or brochure and Underlying Funds prosectuses. Please read the prospectuses and brochure carefully before investing. The prospectuses and brochure can be obtained by mail or by calling 1-800-468-3785.

The total return figures for periods extending beyond a year are average rates of return and do not reflect the Funds' actual year-to-year results, which varied over the periods shown. Contributions or withdrawals made within a period would experience different rates of return based on the unit values on the dates of such transactions.

Portfolio Turnover Rate(%): 30%*

*Excludes all short-term securities.

Stephen J. Rich, Executive Vice President of the Adviser, manages the Mid Cap Value Fund. He joined the Adviser in February 2004 from his position as Vice President, Senior Portfolio Manager at J.P. Morgan Fleming Investment Management Inc. He has approximately 21 years of experience selecting securities for and managing equity portfolios. Mr. Rich was a portfolio manager at J.P. Morgan Fleming for 2 years prior to joining the Adviser where he was responsible for managing small cap portfolios.