GREAT-WEST LIFE & ANNUITY INSURANCE COMPANY
8515 East Orchard Road
Greenwood Village, CO 80111
April 24, 2015
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Great-West Life & Annuity Insurance Company (“Great-West”) |
| Variable Annuity-8 Series Account (the “Registrant”) |
| Initial Registration Statement on Form N-4 for the SecureFoundation Variable Annuity |
| File Nos. 811-23050 & 333- |
Commissioners:
On behalf of Great-West and the Registrant, filed herewith is the above-captioned initial registration statement (“Registration Statement”) under the Securities Act of 1933 (“Securities Act”) and the Investment Company Act of 1940 (“1940 Act”). Registrant is filing the Registration Statement for the purposes of registering a new group variable deferred annuity contract with a guaranteed lifetime withdrawal benefit to be issued to 403(b) plans by Great-West through the Registrant, a separate account of Great-West.
To facilitate the Commission staff’s review of the Registration Statement, we are providing a courtesy copy of the Registration Statement to Mr. Patrick Scott in the Division of Investment Management, Disclosure Review Office No. 3.
Please direct any question or comment regarding the Registration Statement to me at (303) 737-4675 or atryan.logsdon@greatwest.com or to Steve Roth of Sutherland Asbill & Brennan LLP at (202) 383-0158.
Sincerely yours,
/s/ Ryan L. Logsdon
Ryan L. Logsdon
Assistant Vice President & Counsel
| cc: | Patrick F. Scott, Esq. |
| Division of Investment Management, Disclosure Review Office No. 3. |
| Steve E. Roth, Esq. |
| Sutherland Asbill & Brennan LLP |
