EXHIBIT 13

            CONSENT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


The Board of Directors
The Travelers Insurance Company:

We consent to the use of our reports included herein or incorporated by
reference herein, and to the reference to our firm under the heading
"Independent Registered Public Accounting Firm" in the Statement of Additional
Information. Our reports covering the December 31, 2003, consolidated financial
statements and schedules of The Travelers Insurance Company and subsidiaries
refer to changes in the Company's methods of accounting for variable interest
entities in 2003, for goodwill and intangible assets in 2002, and for derivative
instruments and hedging activities and for securitized financial assets in 2001.

/s/ KPMG LLP

Hartford, Connecticut
October 12, 2004