November 15, 2016
Deborah D. Skeens
Senior Counsel
Office of Insurance Products
Division of Investment Management
U.S Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-0506
RE: Registration Statement for Pacific Navigator Individual Flexible Premium Deferred Variable Annuity (333-212626) funded by Separate Account A (File Number 811-09203) of Pacific Life & Annuity Company, Request for Acceleration
Pursuant to Rule 461 under the Securities Act of 1933, we hereby request on behalf of Pacific Life & Annuity Company and Pacific Select Distributors, Inc. (collectively “Registrants”), acceleration of the effective date of the above referenced Registration Statement to November 18, 2016, or as soon thereafter as practicable.
| Sincerely, | |
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| SEPARATE ACCOUNT A OF PACIFIC LIFE & ANNUITY COMPANY | |
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| By: | /s/ Brandon J. Cage |
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| Brandon J. Cage |
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| Assistant Vice-President, Counsel |
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| PACIFIC SELECT DISTRIBUTORS, INC. | |
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| By: | /s/ Adrian S. Griggs |
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| Adrian S. Griggs |
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| Chief Executive Officer |