 | Administrative Office: 4333 Edgewood Road NE Cedar Rapids, IA 52499 | |
December 5, 2011
Mr. Craig Ruckman
Staff Attorney – Office of Insurance Products
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549-0506
| Re: | Post-Effective Amendment No. 22 to the Registration Statement on Form N-4 for Transamerica Life Insurance Company, Separate Account VA X (File No. 333-125817) |
Dear Mr. Ruckman:
Enclosed is one copy of the above-referenced Prototype Registration Statement that was filed with the Securities and Exchange Commission by Transamerica Life Insurance Company (“Transamerica”) as Post-Effective Amendment No. 22 on December 5, 2011 pursuant to paragraph (a) of Rule 485 under the Securities Act of 1933. This Prototype Registration Statement is filed in conjunction with Transamerica’s request, dated December 5, 2011, for permission to file post-effective amendments to certain other registration statements on Form N-4 pursuant to paragraph (b)(1)(vii) of Rule 485. A copy of Transamerica’s (b)(1)(vii) request is attached.
For your reference, Transamerica has included one copy of the Prototype Registration Statement’s Flexible Premium Variable Annuity - I Supplement. Transamerica is filing the Registration Statement in order to change fees, withdrawal percentages, and designated funds to certain GLWB Riders.
Except for these changes in the copy of the Registration Statement, the disclosure in the Registration Statement is the same as the disclosure in the currently effective Registration Statement previously reviewed by the Commission. Therefore, pursuant to Investment Company Act Release No. 13768, Transamerica respectfully requests selective review of the Registration Statement.
If you have any comments or questions regarding the filing, please call Sandy Dix at (319) 355-8427 or Darin Smith at
(319) 355-8330.
Very truly yours,
/s/ Sandy K. Dix
Sandy K. Dix
Manager – Registered Product and Distribution
Enclosures
