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| THE HARTFORD |
May 8, 2012
VIA EDGAR
Ms. Deborah D. Skeens
Senior Counsel — Office of Insurance Products
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-8269
Attn: Division of Investment Management
Re:
Hartford Life Insurance Company Separate Account Seven |
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Hartford’s Personal Retirement Manager III |
| 333-176150 |
| Accession No. 0001104659-12-034397 |
| 811-04972 |
Hartford’s Personal Retirement Manager Select III |
| 333-176149 |
| Accession No. 0001104659-12-034403 |
| 811-04972 |
Hartford’s Personal Retirement Manager V-A Series III |
| 333-176151 |
| Accession No. 0001104659-12-034400 |
| 811-04972 |
Hartford Life and Annuity Insurance Company Separate Account Seven |
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Hartford’s Personal Retirement Manager III |
| 333-176152 |
| Accession No. 0001104659-12-034399 |
| 811-09295 |
Hartford’s Personal Retirement Manager V-A Series III |
| 333-176153 |
| Accession No. 0001104659-12-034401 |
| 811-09295 |
Dear Ms. Skeens:
Pursuant to Investment Company Act Release No. 13768 (February 15, 1984), we respectfully request selective review of the above-referenced initial filings.
The referenced registration statements filed with the Securities and Exchange Commission on May 8, 2012 are substantially identical to the post-effective amendment filings reflected in the following table, which were initially filed on February 1, 2012:
Hartford Life Insurance Company Separate Account Seven |
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Hartford’s Personal Retirement Manager III |
| 333-176150 |
| Accession No. 0001104659-12-005727 |
| 811-04972 |
Hartford’s Personal Retirement Manager Select III |
| 333-176149 |
| Accession No. 0001104659-12-005729 |
| 811-04972 |
Hartford’s Personal Retirement Manager V-A Series III |
| 333-176151 |
| Accession No. 0001104659-12-005730 |
| 811-04972 |
Hartford Life and Annuity Insurance Company Separate Account Seven |
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Hartford’s Personal Retirement Manager III |
| 333-176152 |
| Accession No. 0001104659-12-005728 |
| 811-09295 |
Hartford’s Personal Retirement Manager V-A Series III |
| 333-176153 |
| Accession No. 0001104659-12-005732 |
| 811-09295 |
These versions were withdrawn at your request in April 2012. The registration statements filed today incorporate all of the staff comments and our responses thereto; therefore, we are requesting expedited
review for today’s filings. All financial statements, exhibits, and other required disclosure not included in these Registration Statements will be filed by post-effective amendment.
The difference between the prior, approved version of the above-referenced products and the versions filed today is that we have removed the conversion option for all riders. The ability for contract owners to post-issue elect the Daily Lock Income Benefit rider remains intact.
Pursuant to Rule 461 under the Securities Act of 1933, each of the undersigned Registrants hereby request that the above referenced Registration Statements electronically filed via Edgar on Form N-4 be accelerated and declared effective on July 16, 2012, or as soon thereafter as is reasonably practicable.
We appreciate your attention to these filings. If you have any comments or questions, please call me at (860) 843-2021.
HARTFORD LIFE INSURANCE COMPANY
HARTFORD LIFE AND ANNUITY INSURANCE COMPANY
HARTFORD LIFE INSURANCE COMPANY
SEPARATE ACCOUNT SEVEN
HARTFORD LIFE AND ANNUITY INSURANCE COMPANY
SEPARATE ACCOUNT SEVEN
By: | David N. Levenson* |
| *By: | /s/ Elizabeth L. Gioia |
| David N. Levenson |
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| Attorney-in-fact |
| President, Chief Executive Officer |
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| and Chairman of the Board |
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HARTFORD SECURITIES DISTRIBUTION COMPANY, INC.
By: | /s/ Sharon A. Ritchey |
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| Sharon A. Ritchey, Senior Vice President |
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* Pursuant to Power of Attorney dated April 1, 2012