Hartford Life Insurance Co Separate Account Seven
Filed: 2 Aug 10, 12:00am
[LOGO]
August 2, 2010
William James Kotapish, Esq.
Assistant Director
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-4644
RE: Hartford Life Insurance Company Separate Account Seven
Registration No. 333-148564; and 811-04972
Rule 485(b)(1)(vii) Request
Dear Mr. Kotapish,
I am writing to you on behalf of the Hartford Life Insurance Company and Hartford Life and Annuity Insurance Company (collectively, “The Hartford”) and the registrants (collectively, the “Registrants”) listed below.
The Registrants request approval, pursuant to Securities Act Rule 485(b)(1)(vii), to file Post-Effective Amendments (the “Replicated Registration Statements”) to the registration statements on Form N-4 listed below, pursuant to the provisions of the Securities Act Rule 485(b):
Registrants |
| Securities Act Nos. |
Hartford Life Insurance Company Separate Account Seven (811-04972): |
| 333-159545 |
|
| 333-148565 |
Hartford Life and Annuity Insurance Company Separate Account Seven (811-09295): |
| 333-159547 |
The Replicated Registration Statements will contain certain revisions that my render them ineligible to be filed under Rule 485(b). However, The Hartford believes the revisions, to be reviewed by the staff under the Rule 485(a) filing made on May 10, 2010 (Accession No. 0001104659-10-027294) will be “substantially identical” to revisions that include responses to SEC comments, that will be set forth in the post-effective amendment under Rule 485(b) to the registration statement on Form N-4 333-148564 (the “Prototype Registration Statement”).
The Registrants make the following representations in support of this request:
· Because the Replicated Registration Statements are substantially identical to the Prototype Registration Statement, the Registrants will be able to revise the Replicated Registration Statements effectively to reflect Commission staff comments made on the Prototype Registration Statement.
· The Registrants will make corresponding changes to the Replicated Registration Statements in response to comments made by the Commission staff on the Prototype Registration Statement.
· The Replicated Registration Statements will not contain any material changes that would make the post-effective amendments ineligible to be filed under Rule 485(b).
Thank you for your consideration in this matter. Please call me at (860) 843-1941 if you have any questions with respect to this request.
Very truly yours,
/s/ Richard J. Wirth |
|
Richard J. Wirth |
|
Assistant General Counsel |
|
cc: Michael Kosoff (SEC)
Sarah M. Patterson (Hartford)