INVESTMENT DISTRIBUTORS, INC.
2801 Highway 280 South · Birmingham, AL · 35223 · (205)268-1000
March 1, 2021
VIA EDGARLINK
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
RE: Protective Life Insurance Company
Registration Statement on Form S-3 for
“Protective Market Defender”
File No. 333-222086
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-3 be accelerated to March 15, 2021 or as soon thereafter as is reasonably practicable.
| Investment Distributors, Inc. |
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| By: | /s/ Barry Brown | |
| Name: | Barry Brown |
| Title: | President and Director |
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March 1, 2021
VIA EDGARLINK
Securities and Exchange Commission
450 Fifth Street, NW
Washington, DC 20549
RE: Protective Life Insurance Company
Registration Statement on Form S-3 for
“Protective Market Defender”
File No. 333-222086
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-3 be accelerated to March 15, 2021 or as soon thereafter as is reasonably practicable.
| Protective Life Insurance Company |
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| By: | /s/ Richard J. Bielen | |
| Name: | Richard J. Bielen |
| Title: | President |