2ND AMENDMENT TO PARTICIPATION AGREEMENT

2ND AMENDMENT TO PARTICIPATION AGREEMENT

This amendment (“Amendment”) is entered into as of the ______ day of April, 2009, by and among SYMETRA LIFE INSURANCE COMPANY, (hereinafter the "Company"), a Washington corporation, on its own behalf and on behalf of each segregated asset account of the Company set forth on Schedule A hereto as may be amended from time to time (each such account hereinafter referred to as the "Account"); and FIDELITY DISTRIBUTORS CORPORATION (hereinafter the "Underwriter"), a Massachusetts corporation; and each of VARIABLE INSURANCE PRODUCTS FUND, VARIABLE INSURANCE PRODUCTS FUND II, VARIABLE INSURANCE PRODUCTS FUND III, VARIABLE INSURANCE PRODUCTS FUND IV, and VARIABLE INSURANCE PRODUCTS FUND V, each an unincorporated business trust organized under the laws of the Commonwealth of Massachusetts (each referred to hereinafter as the "Fund").

WHEREAS, the Parties have previously executed a Fund Participation Agreement dated February 2, 2007 as amended (the “Agreement”);     

NOW THEREFORE, in consideration of the terms, covenants and conditions contained herein and other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the Parties agree to amend the Agreement as follows:

1. Schedule A of the agreement is replaced with Schedule A attached hereto.

To the extent possible, this Amendment and the Agreement shall be read together. In the event of a conflict between the provisions of this Amendment and those of the Agreement, the provisions of this Amendment shall control.

Except as expressly amended hereby, the Agreement remains in full force and effect.

IN WITNESS WHEREOF, each of the parties hereto has caused this Agreement to be executed in its name and on its behalf by its duly authorized representative.

SYMETRA LIFE INSURANCE COMPANY

By: _________________________

Name: Xxxxx X. Xxxxxxxx

Title: Vice President

VARIABLE INSURANCE PRODUCTS FUND,

VARIABLE INSURANCE PRODUCTS FUND II

VARIABLE INSURANCE PRODUCTS FUND III, and

VARIABLE INSURANCE PRODUCTS FUND IV

VARIABLE INSURANCE PRODUCTS FUND V

By: ________________________

Name: Xxxxx Xxxxxxxx

Title: Deputy Treasurer

FIDELITY DISTRIBUTORS CORPORATION

By: _______________________

Name: Xxxx Xxxxxxxx

Title: EVP, Institutional

Schedule A

Separate Accounts and Associated Contracts

Name of Separate Account and Policy Form Numbers of Contracts

Date Established by Board of Directors Funded By Separate Account

Symetra Separate Account SL Premier Accumulation Life

November 6, 1986 Enhanced Accumulation Life

Symetra Complete

Symetra Complete Advisor

Symetra Separate Account C Spinnaker

September 14, 1993 Spinnaker Advisor

Spinnaker Choice

Focus

Retirement Passport GVA

Symetra Resource Variable Account B Spinnaker Plus

February 6, 1986

Unregistered Accounts

Symetra Separate Account D Symetra GVA

Symetra Separate Account VL VBOLI

July 29, 2008 VBOLIX