October 23, 2007
Mr. Mark Cowan
Office of Insurance Products
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549-0506
Re: | Western Reserve Life Assurance Co. of Ohio |
Separate Account VA AA |
Flexible Premium Variable Annuity - M |
Pre-Effective Amendment No. 1 on Form N-4 |
File Nos.: 333-145461; 811-22113 |
Dear Mr. Cowan:
Western Reserve Life Assurance Co. of Ohio filed the Pre-Effective Amendment No. 1 to the above-referenced Form N-4 registration statement on October 23, 2007. Pursuant to Rule 461 under the Securities Act of 1933, Western Reserve Life Assurance Co. of Ohio and the principal underwriter, Transamerica Capital, Inc., now respectfully request that the effective date of the registration statement be accelerated and that the registration statement be declared effective October 23, 2007 or as soon thereafter as practicable.
Western Reserve Life Assurance Co. of Ohio acknowledges the following:
• | should the Commission or the staff pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
• | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the insurance company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and |
• | the insurance company may not assert this action as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Western Reserve Life Assurance Co. of Ohio | Transamerica Capital, Inc. | |||||||
By: | /s/ Darin D. Smith | By: | /s/ Robert Frederick | |||||
Darin D. Smith | Robert Frederick | |||||||
Vice President | Managing Director and Exec VP |
cc: | Frederick R. Bellamy, Esq. |