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 | | Transamerica Life Insurance Company Administrative Office: 4333 Edgewood Road NE – MS 4240 Cedar Rapids, IA 52499 |
October 28, 2011
Craig Ruckman, Esq.
Office of Insurance Products
U.S. Securities and Exchange Commission
100 F St. NE
Washington, DC 20549-0506
| Re: | Selective Review – Initial Filing |
| | Flexible Premium Variable Annuity – U |
| | File Nos.: 333-177584; 811-22622 |
| | Transamerica Life Insurance Company |
Dear Mr. Ruckman:
The above-referenced initial filing was made on October 28, 2011 (accession number is 0001193125-11-285817). The Flexible Premium Variable Annuity – U version is substantially similar to the Flexible Premium Variable Annuity – I product. We have already provided under separate cover, a black-lined comparison of the two products to hi-light all the differences.
The following changes are the main differences in the above referenced filing:
| • | | Changes in the available Investment Choices. |
| • | | The Annual Step-Up Death Benefit is not available under this product. |
| • | | There is no Fund Facilitation Fee. |
| • | | The following optional riders are not available under this product: |
| • | | Additional Death Distribution |
| • | | Additional Death Distribution+ |
| • | | Retirement Income Choice® 1.2 Rider |
| • | | The Retirement Income Max Rider which is available, is identical to the recent “A” filing made on Flex-I except for differences in the Designated Investment Options. |
We hereby request Selective Review pursuant to SEC Release No.: 33-6510 (February 15, 1984) for the above-referenced Flexible Premium Variable Annuity – U product filing.
This letter will also be filed as a correspondence filing via EDGAR.
Very truly yours,
Transamerica Life Insurance Company
/s/Darin D. Smith
Darin D. Smith
General Counsel
Transamerica Capital Management
Member of the
Group