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| Sarah M. Patterson |
| AVP and Senior Counsel |
| Law Department |
| Direct Dial: | (860) 843-60851 |
| Fax: | (860) 380-1616 |
July 29, 2011
VIA EDGAR AND EMAIL
Ms. Deborah D. Skeens
Senior Counsel
Office of Insurance Products
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-8629
RE: Hartford Life Insurance Co Separate Account Seven
Initial Registration Statement on Form N-4
Files Nos. 333-174678; 811-04972
Hartford Life & Annuity Insurance Co Separate Account Seven
Initial Registration Statement on Form N-4
Files Nos. 333-174679; 811-09295
Dear Ms. Skeens:
Presented below and attached hereto please find specific responses to each of your comments and questions from July 28, 2011:
1. General
COMMENT: Please confirm that the name of each Portfolio Company, not the Series Trust, is displayed on the cover page.
RESPONSE: Agreed. Registrant confirms.
2. Dollar Cost Averaging Program (p. 14)
COMMENT: Please revise the sentence referring to the interest credited.
RESPONSE: Agreed.
3. Automatic Income Program (p. 15)
COMMENT: Please clarify cross-references for consistency.
RESPONSE: Agreed.
4. Premium Based Charge (p. 18)
a. COMMENT: Please clarify the language referencing the “breakpoint range” for clarity.
RESPONSE: Agreed.
b. COMMENT: Please revise the sentence referencing the duration of the Premium Based Charge schedule “reducing” to 0%.
RESPONSE: Agreed.
5. Payment Base (p. 38)
COMMENT: Please revise the language regarding the application of the Payment Base cap for “new sales only.”
RESPONSE: Agreed.
6. Glossary (p. 50)
COMMENT: Please clarify the definition of Dollar Cost Averaging.
RESPONSE: Agreed.
7. CDSC Examples (pp. A-2 - A-8)
COMMENT: Examples 1 through 5 state that “[s]tep 1 does not apply” but do not describe this step. Please identify Step 1 in these examples and explain why it does not apply.
RESPONSE: Agreed. In addition, we added the word “step” to each corresponding step in the CDSC section of the prospectus.
8. Income Foundation Builder Examples (p. A-20)
COMMENT: Please clarify Footnote three of example one referring to the Deferral Credit Base.
RESPONSE: Agreed.
Thank you.
Best Regards, | |
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/s/ Sarah M. Patterson | |
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