1(212) 318-6275
rachaelschwartz@paulhastings.com
| May 20, 2013 | 90368.00002 |
VIA EDGAR
Ms. Christina DiAngelo
Mr. James O’Connor
U.S. Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549
| Re: | SunAmerica Series, Inc. |
| File Nos.: 333-187946 and 811-07797 |
| SunAmerica Specialty Series |
| File Nos.: 333-187956 and 811-21482 |
| (each, a “Registrant” and collectively, the “Registrants”) |
Dear Ms. DiAngelo and Mr. O’Connor:
This letter is being filed to revise the response to Comment #23, which was filed as part of a CORRESP filing on May 15, 2013, in order to respond to Staff comments with respect to: (i) the Registration Statement on Form N-14 of SunAmerica Series, Inc. (the “Corporation”), which was filed with the Securities and Exchange Commission (“Commission”) on April 16, 2013 (SEC Accession No. 0001193125-13-156962), for the purpose of reorganizing the Focused Small-Cap Value Portfolio into the SunAmerica Strategic Value Portfolio, each a series of the Corporation, and (ii) the Registration Statement on Form N-14 of SunAmerica Specialty Series (the “Trust”), which was filed with the Commission on April 17, 2013 (SEC Accession No. 0001193125-13-158352), for the purpose of reorganizing the Focused Small-Cap Growth Portfolio, a series of the Corporation, into the SunAmerica Focused Alpha Growth Fund, a series of the Trust (each, a “Registration Statement” and collectively, the “Registration Statements”).
Comment #23:On page 9, Fee Tables, you have asked us to confirm whether the Total Annual Portfolio Operating Expense after Fee Waiver and/or Expense Reimbursement (Recoupment) of 1.68% for the Pro Forma Combined Portfolio—Class A reflects any recouped expenses.
Response #23: The Trust confirms that the amount shown under the Total Annual Portfolio Operating Expense after Fee Waiver and/or Expense Reimbursement (Recoupment) for the Pro Forma Combined Portfolio—Class A reflects 0.01% of recouped expenses and the fee table and examples in the Registration Statement have been revised to reflect the 0.01% of recouped expenses.
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Should you have any questions regarding the foregoing, please do not hesitate to contact the undersigned at the number listed above. Thank you.
| Paul Hastings LLP | 75 East 55th Street | New York, NY 10022 |
| t: +1.212.318.6000 | www.paulhastings.com |
May 20, 2013
Page 2
Very truly yours,
/s/ Rachael L. Schwartz
Rachael L. Schwartz
for PAUL HASTINGS LLP
| CC: | John E. McLean, Esq., SunAmerica Asset Management Corp. |
| Christopher J. Tafone, Esq., Paul Hastings LLP |