[Logo]
Ohio National Financial Services
One Financial Way
Cincinnati, Ohio 45242
VIA EDGAR CORRESPONDENCE
March 6, 2013
Ms. Michelle Roberts
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F. Street, N.E.
Washington, D.C. 20549-0506
Re: | Ohio National Variable Account A |
ONcore Premier (sold on or after October 1, 2012) Individual Variable Annuity
Post-Effective Amendment No. 1
File Nos. 811-01978 & 333-182250
Dear Ms. Roberts:
This letter is to generally describe changes made in the above-referenced post-effective amendment (the “Post-Effective Amendment”) filed by Registrant on February 26, 2013 pursuant to Rule 485(a) under the Securities Act of 1933 (“1933 Act”). Registrant filed 16 other post-effective amendments with the Commission between February 27, 2013 and March 1, 2013 pursuant to Rule 485(a) under the 1933 Act (collectively, along with the Post-Effective Amendment, the “filings”). The filings include the following:
Product filing | 40 Act File No. | 33 Act File No. | ||
ONcore Premier (sold on or after October 1, 2012), Post-Effective Amendment No. 1 | 811-01978 | 333-182250 | ||
ONcore Value (sold on or after October 1, 2012), Post-Effective Amendment No. 1 | 811-01978 | 333-182248 | ||
ONcore Xtra (sold on or after October 1, 2012), Post-Effective Amendment No. 1 | 811-01978 | 333-182249 | ||
ONcore Value (sold before October 1, 2012), Post-Effective Amendment No. 51 | 811-01978 | 333-43513 | ||
ONcore Xtra (sold before October 1, 2012), Post-Effective Amendment No. 42 | 811-01978 | 333-86603 | ||
ONcore Premier (sold before October 1, 2012), Post-Effective Amendment No. 48 | 811-01978 | 333-43515 | ||
ONcore Wrap, Post-Effective Amendment No. 24 | 811-01978 | 333-134982 | ||
ONcore Flex, Post-Effective Amendment No. 45 | 811-01978 | 333-43511 | ||
ONcore Lite, Post-Effective Amendment No. 39 | 811-01978 | 333-52006 | ||
ONcore Ultra, Post-Effective Amendment No. 21 | 811-01978 | 333-134288 | ||
ONcore Lite II, Post-Effective Amendment No. 19 | 811-01978 | 333-156430 | ||
ONcore Ultra II, Post-Effective Amendment No. 19 | 811-01978 | 333-156432 | ||
ONcore Lite III, Post-Effective Amendment No. 12 | 811-01978 | 333-164075 |
Ms. Roberts
March 6, 2013
Page 2 of 3
ONcore Flex II, Post-Effective Amendment No. 12 | 811-01978 | 333-164069 | ||||||
ONcore Xtra II, Post-Effective Amendment No. 12 | 811-01978 | 333-164073 | ||||||
ONcore Premier II, Post-Effective Amendment No. 12 | 811-01978 | 333-164070 | ||||||
ONcore Premier WF, Post-Effective Amendment No. 9 | 811-01978 | 333-171785 |
Capitalized terms used herein have the meanings given to them in the filings. The filings were generally made to include the following changes:
• | GLWB Preferred I.S. – Add a new version of a GLWB rider (single and joint), the GLWB Preferred I.S. The GLWB Preferred I.S. rider is similar to the existing GLWB Plus that Registrant offers, except that (a) the lifetime annuity amount received during the Lifetime Annuity Period is determined by a formula based on average U.S. Treasury rates, (b) the annual credit period is 15 years and does not re-start upon a step-up and (c) the annual credit is pro-rated for withdrawals that are less than the maximum annual withdrawal under the rider. |
• | GLWB Plus – Incorporate changes that have been made to the GLWB Plus (single and joint) since May 1, 2012, including reductions in maximum annual withdrawal rates and annual credit rates. Add a new age band at age 70 and increase the fees effective May 1, 2013. |
• | GMIB – Increase the fees for certain versions of GMIB riders the Registrant offered in the past. |
• | ARDBR – Increase the fees for certain versions of the ARDBR death benefit riders the Registrant offered in the past. |
The GLWB Preferred I.S. rider is included in 9 of the filings; the GLWB Plus in all 17 filings; and the GMIB and ARDBR in 9 filings. The following table indicates which of the above changes are included in the individual filings:
| GLWB Preferred I.S. | GLWB Plus | GMIB | ARDBR | |||||
ONcore Premier (sold on or after October 1, 2012) (333-182250) | Included | Included | NA | NA | ||||
ONcore Value (sold on or after October 1, 2012) (333-182248) | Included | Included | NA | NA | ||||
ONcore Premier WF (333-171785) | Included | Included | NA | NA | ||||
ONcore Premier II (333-164070) | Included | Included | NA | NA | ||||
ONcore Flex II (333-164069) | Included | Included | NA | NA | ||||
ONcore Lite III (333-164075) | Included | Included | NA | NA | ||||
ONcore Lite II (333-156430) | Included | Included | Included | Included | ||||
ONcore Ultra II (333-156432) | Included | Included | Included | Included | ||||
ONcore Wrap (333-134982) | Included | Included | Included | Included | ||||
ONcore Xtra (sold on or after October 1, 2012) (333-182249) | NA | Included | NA | NA | ||||
ONcore Xtra II (333-164073) | NA | Included | NA | NA | ||||
ONcore Premier (sold before October 1, 2012) (333-43515) | NA | Included | Included | Included | ||||
ONcore Value (sold before October 1, 2012) (333-43513) | NA | Included | Included | Included | ||||
ONcore Xtra (sold before October 1, 2012) | NA | Included | Included | Included | ||||
Ms. Roberts
March 6, 2013
Page 3 of 3
ONcore Lite (333-52006) | NA | Included | Included | Included | ||||
ONcore Ultra (333-134288) | NA | Included | Included | Included | ||||
ONcore Flex (333-43511) | NA | Included | Included | Included |
Please contact me at (513) 794-6278 should you have any questions.
Sincerely,
/s/ Kimberly A. Plante
Kimberly A. Plante
Senior Associate Counsel
