April 16, 2008
VIA EDGAR
Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
Division of Investment Management
100 F Street N.E.
Washington, D.C. 20549
Re: VALIC Separate Account A ("Registrant")
SPIVA Single Premium Immediate Variable Deferred Annuity
The Variable Annuity Life Insurance Company ("Depositor")
Form N-4 under the Securities Act of 1933, as amended (the "1933 Act") and the Investment Company Act of 1940 ("1940 Act")
File Nos.: 333-124756 and 811-03240
EDGAR Submission Type RW
Withdrawal of Registration Statement Pursuant to Rule 477 of the 1933 Act
Ladies and Gentlemen:
Pursuant to Rule 477 of the 1933 Act, the Registrant, a separate account of The Variable Annuity Life Insurance Company, hereby respectfully requests that the Securities and Exchange Commission (the "Commission") consent to the withdrawal of the Registrant's registration statement on Form N-4 (File nos. 333-124756 and 811-03240), filed with the Commission on March 10, 2006, accession number 0000354912-06-000024, along with any amendments or exhibits filed thereto (the Registration Statement").
The SPIVA Single Premium Immediate Variable Deferred Annuity (the "Product"), was never declared effective. The Registrant determined not to proceed with the registration and sale of the securities covered by the Registration Statement. No securities were sold in connection with the Product.
Accordingly, we respectfully request that the Commission grant an order for the withdrawal of the Registration Statement as soon as possible.
Please contact me at 713-831-3164 if you have any questions or need more information.
Sincerely,
/s/ KATHERINE STONER
Katherine Stoner
Deputy General Counsel, Vice President and Secretary
cc: Rebecca Marquigny
Office of Insurance Products