WITNESSETH

                                                                 EX-99.23(h)(13)

                     AMENDMENT TO TRANSFER AGENCY AGREEMENT
                            JNLNY VARIABLE FUND I LLC

         AMENDMENT made as of this 4th day of October, 2004, by and between
JNLNY Variable Fund I LLC, a Delaware limited liability corporation ("the
Variable Fund"), and Xxxxxxx National Asset Management, LLC, a Michigan limited
liability company ("JNAM").

                                   WITNESSETH

         WHEREAS, the Variable Fund and JNAM entered into a Transfer Agency
Agreement (the "Agreement") dated January 31, 2001;

         WHEREAS, under the terms of the Agreement, JNAM renders certain
transfer agency and other services to units of beneficial interest in separate
Funds ("Fund") of the Variable Fund and the owners of record thereof; and

         WHEREAS, new funds have been added.

         NOW THEREFORE, in consideration of the mutual covenants herein
contained, the parties hereby agree to amend the Agreement as follows:

1.            Exhibit A to the Agreement is hereby deleted and replaced in its
              entirety with Exhibit A dated October 4, 2004, attached hereto.

         IN WITNESS WHEREOF, the parties have caused this instrument to be
executed as of the day and year first above written.

ATTEST:                                     JNLNY VARIABLE FUND I LLC


___________________________                 By:______________________________
                                               Xxxxx X. Xxxx
                                               As Its Vice President, Counsel
                                               and Secretary

ATTEST:                                     XXXXXXX NATIONAL ASSET
                                            MANAGEMENT, LLC

___________________________                 By:______________________________
                                               Xxxxxx X. Xxxxxxx
                                               As Its President





                                    EXHIBIT A

                                 OCTOBER 4, 2004


                  JNL/Mellon Capital Management the Xxx XX 10 Fund
                  JNL/Mellon Capital Management the S&P(R) 10 Fund
                  JNL/Mellon Capital Management Global 15 Fund
                  JNL/Mellon Capital Management 25 Fund
                  JNL/Mellon Capital Management Select Small-Cap Fund
                  JNL/Mellon Capital Management Nasdaq(R) 15 Fund
                  JNL/Mellon Capital Management Value Line(R) 25 Fund