INVESTMENT DISTRIBUTORS, INC.
2801 Highway 280 South · Birmingham, AL · 35223 · (205)268-1000
April 12, 2011
VIA EDGARLINK
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
RE: | Protective Life Insurance Company |
| Post-Effective Amendment No. 2 to the Registration Statement on Form S-1 for Modified Guaranteed Annuity Contracts |
| “Prosaver Platinum” |
| File No. 333-158611 |
Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, Investment Distributors, Inc., as principal underwriter, hereby joins in a request by the above referenced Registrant that the effective date of the above-captioned registration statement filed on Form S-1 be accelerated to April 30, 2011 or as soon thereafter as is reasonably practicable.
| Investment Distributors, Inc. |
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| By: | /s/ Edwin V. Caldwell, II |
| Name: | Edwin V. Caldwell, II |
| Title: | President and Director |
April 12, 2011
VIA EDGARLINK
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
RE: | Protective Life Insurance Company |
| Post-Effective Amendment No. 2 to the Registration Statement on Form S-1 for Modified Guaranteed Annuity Contracts |
| “Prosaver Platinum” |
| File No. 333-158611 |
Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, the Registrant referenced above hereby requests that the effective date of the above-captioned registration statement filed on Form S-1 be accelerated to April 30, 2011 or as soon thereafter as is reasonably practicable.
| Protective Life Insurance Company |
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| By: | /s/ John D. Johns |
| Name: | John D. Johns |
| Title: | President |
