VIA EDGAR
October 3, 2008
Michael L. Kosoff
Securities and Exchange Commission
Division of Insurance Products
450 Fifth Street N.W., Room 5206
Washington, DC 20549
| | | |
| Re: | | Principal Life Insurance Company Variable Life Separate Account |
| | | Principal Benefit Variable Universal Life II (BVUL II) |
| | | Registration Statement on Form N-6, File Nos. 333-149363; 811-05118 |
| | | |
| | | Pre-effective Amendment #1: |
| | | File # 333-149363 and No. 811-05118 |
| | | Accession # 0000950137-08-009756 |
| | | |
| | | Pre-effective Amendment #2: |
| | | File # 333-149363 and No. 811-05118 |
| | | Accession #: 0000950137-08-012277 |
Dear Mr. Kosoff:
As we discussed yesterday, this letter is to confirm that pursuant to Rule 461, Principal Life Insurance Company and Princor Financial Services Corporation, as principal underwriter, request acceleration of the effective date of the registration statement for the Principal Benefit Variable Universal Life II (referenced above) to October 3, 2008, or such later date as is reasonably practicable.
We understand that the registrant is responsible for the accuracy and adequacy of the disclosures in the filing and that staff comments or our changes to the disclosures in response to staff comments do not foreclose the Commission from taking any action with respect to the filing. In addition, we understand that we may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the Federal securities laws of the United States.
We thank you for your assistance with this filing.
Sincerely yours,
| | | |
| Principal Life Insurance Company | | Princor Financial Services Corporation |
| | | | | | | |
| By: | | /s/Patrick Kirchner | | By: | | /s/Sarah J. Pitts |
| | | Assistant General Counsel | | | | Counsel |
