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Allstate (R)
FINANCIAL
March 23, 2020
BY EDGAR
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: Allstate Financial Advisors Separate Account I (“Registrant”)
Allstate Life Insurance Company (“Depositor”)
Post-Effective Amendment No. 19 to Registration Statement on Form N-4
File Nos. 333-114560; 811-09327
Dear Sir/Madam:
On behalf of the above-named Registrant, filed herewith is one electronically formatted copy of the above-referenced post-effective amendment to the registration statement on Form N-4 (“N-4 Registration Statement”) under the Securities Act of 1933 (“1933 Act”) and the Investment Company Act of 1940 (“1940 Act”).
Pursuant to Rule 485(a) under the 1933 Act, this Registration Statement is being filed in order to reflect the conversion from Form S-3 to Form S-1 of the registration statement for the registered Market Value Adjusted (“MVA”) Interests under the combination variable/MVA annuity contracts offered under the N-4 Registration Statement. No material changes have been made to the disclosure in the N-4 Registration Statement aside from changes needed to reflect the conversion of the registration of the offering of MVA interests from Form S-3 to Form S-1, Accordingly, we are requesting selective review of the referenced N-4 Registration Statement with respect to the MVA disclosure.
If you have any questions, please do not hesitate to contact me at 402-975-6368. Thank you.
Very truly yours,
/s/JAN FISCHER-WADE
JAN FISCHER-WADE
Enclosure
