MAX BERUEFFY
Senior Associate Counsel
Writer’s Direct Number: (205) 268-3581
Facsimile Number: (205) 268-3597
Toll-Free Number: (800) 627-0220
E-mail: max.berueffy@protective.com
February 29, 2016
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
RE: | Protective Life Insurance Company |
| Registration Statement on Form S-3 |
| For Modified Guaranteed Annuity Contracts |
| “Prosaver Platinum” |
Dear Commissioners:
Protective Life Insurance Company (the “Company”) is transmitting the Registration Statement on Form S-3 referenced above for filing with the Securities and Exchange Commission (the “Commission”). This Registration Statement relates to certain modified guaranteed annuity contracts (the “Contracts”) issued by the Company.
We will be filing a pre-effective amendment along with acceleration requests from the Company and the underwriter of the Contracts, requesting an effective date of May 1, 2016 for the Registration Statement.
The Company acknowledges that:
· should the Commission or the staff acting 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 registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
· the registrant 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.
If you have any questions or comments about this filing, please contact the undersigned at (205) 268-3581 or Thomas Bisset at (202) 383-0118.
Very truly yours,
/s/ Max Berueffy |
|
Max Berueffy |
|
Senior Associate Counsel |
|
cc: Ms. Sally Samuel
Mr. Keith Gregory
Mr. Thomas Bisset
