MAX BERUEFFY
Senior Associate Counsel
Writer’s Direct Number: (205) 268-3581
Facsimile Number: (205) 268-3597
Toll-Free Number: (800) 627-0220
| December 15, 2017 |
VIA EDGAR and E-MAIL
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: Protective Life Insurance Company
Registration Statement on Form S-3
For Protective Market Defender Limited Flexible Premium Deferred Annuity Contracts
Dear Commissioners:
I have enclosed, as a courtesy to you, a copy of Protective Life Insurance Company’s (the “Company”) Registration Statement on Form S-3 filed with the Securities and Exchange Commission (the “Commission”) on December 15, 2017. This Registration Statement relates to Protective Market Defender limited flexible premium deferred annuity contracts (the “Contracts”) issued by the Company.
We expect to file a pre-effective amendment including the auditor’s consent and incorporating by reference the financial statements as of December 31, 2017; as soon as possible after the Company’s Annual Report on Form 10-K is filed. At that time, we will also submit acceleration requests from the Company and the underwriter of the Contracts, requesting an effective date of May 1, 2018 for the Registration Statement.
If you have any questions or comments regarding the Registration Statement, or if there is anything that we can do to facilitate the Staff’s review of the Registration Statement, please contact me at (205) 268-3581 or Thomas Bisset at (202) 383-0118.
Very truly yours,
Max Berueffy
Senior Associate Counsel
cc: Ms. Sally Samuel
Mr. Keith Gregory
Mr. Thomas Bisset
