Ex. 99-B.8.51 Form of First Amendment dated ________________, 2000 to the Services Agreement by and among Aetna Investment Services, Inc. and Federated Administrative Services.

                                  Ex. 99-B.8.51
 Form of First Amendment dated ________________, 2000 to the Services Agreement
                  by and among Aetna Investment Services, Inc.
                     and Federated Administrative Services.

                FIRST AMENDMENT TO SHAREHOLDER SERVICES AGREEMENT

THIS FIRST AMENDMENT TO THE SERVICES AGREEMENT (the "First Amendment") is made
and entered into as of the __ day of August, ____ by and among AETNA INVESTMENT
SERVICES, INC. ("AISI") and FEDERATED ADMINISTRATIVE SERVICES ("FEDERATED").

                                   WITNESSETH

       WHEREAS, AISI and FEDERATED are parties to a Shareholder Services
Agreement dated October 4, 1999, (the "Agreement"); and

       WHEREAS, the parties now desire to modify the Agreement in order to allow
AISI to make shares of certain funds available to certain separate accounts of
Aetna Life Insurance and Annuity Company ("ALIAC"), interests of which may be
offered to contract holders through certain variable annuity contracts, for
which AISI will perform administrative services.

       NOW, THEREFORE, in consideration of the premises and mutual covenants and
promises expressed herein, the parties agree as follows:

1      The parties hereby agree that AISI shall be authorized to make shares of
       the funds covered by the Agreement available for purchase by Variable
       Annuity Accounts B, C, D and F of ALIAC, subject to the terms, including
       compensation to be paid to AISI for such services, of the Agreement.

2      In the event that there is any conflict between the terms of this First
       Amendment and the Agreement it is the intention of the parties hereto
       that the terms of this First Amendment shall control, and the Agreement
       shall be interpreted on that basis. To the extent that the provisions of
       the Agreement have not been amended by this First Amendment, the parties
       hereto confirm and ratify the Agreement.

IN WITNESS WHEREOF, the parties have executed this First Amendment as of the
date first written.


                      AETNA INVESTMENT SERVICES, INC.
                                       By:___________________________________
                                       Name:_________________________________
                                       Title:________________________________

                      FEDERATED ADMINISTRATIVE SERVICES
                                       By:___________________________________
                                       Name:_________________________________
                                       Title:________________________________