Pacific Life & Annuity Company
700 Newport Center Drive
Newport Beach, California 92660-6397
November 12, 2019
Sally Samuel
Branch Chief
Office of Insurance Products
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0506
Re: Post-Effective Amendment No. 17 for Pacific Odyssey Variable Annuity (File Number 333-185329) funded by Separate Account A of Pacific Life & Annuity Company (File Number 811-09203); Request for Withdrawal of Post-Effective Amendment
Dear Ms. Samuel:
Pursuant to Rule 477(a) of the Securities Act of 1933, as amended, and on behalf of Pacific Life & Annuity Company (“Pacific Life”) and Separate Account A of Pacific Life, we hereby request the withdrawal of Post-Effective Amendment No. 17 (“Amendment”) to the above referenced Registration Statement, filed on October 18, 2019.
We request withdrawal of the Amendment since we will not proceed with the product modifications within the time frame indicated in the Amendment. As a result, we respectfully request withdrawal of the Amendment as soon as practicable.
No securities were sold in connection with this Amendment.
Please note that we are filing this application to request a withdrawal of the above referenced Amendment only and are not applying for withdrawal of the entire Registration Statement.
If you have any questions regarding this matter, please contact the undersigned at (949) 219-3943.
Sincerely,
/s/ Brandon J. Cage
Brandon J. Cage
Assistant Vice President, Counsel