Ameritas Life Insurance Corp. 5900 O Street / Lincoln, NE 68510 |  |
December 8, 2015
Via EDGAR and Overnight Delivery
Laura Riegel, Senior Counsel
Disclosure Review and Accounting Office
Division of Investment Management
Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549
| Re: | Registration Statement for Ameritas Life Insurance Corp. ("Depositor" or "Ameritas Life") andAmeritas Variable Separate Account VA-2 (1940 Act No. 811-05192) ("Registrant" or "Separate Account") |
| Direction Variable Annuity (1933 Act No. 333-206889) | |
Pre-Effective Amendment No. 2 on Form N-4
Acceleration Request Pursuant to Rule 17 CFR 230.461 to December 9, 2015, or soon thereafter |
Dear Ms. Riegel:
TheRegistrant andthe Principal Underwriter, Ameritas InvestmentCorp., hereby request that the effective date of the above captioned Pre-Effective Amendment No. 2 to the Registration Statement be accelerated to December 9, 2015, or soon thereafter.
In support of this request, we state:
| (i) | The initial Form N-4 filing for Registration Statement No. 333-206889 was submitted via EDGAR and by overnight mail to the Division of Investment Management on September 11, 2015. We received a letter dated November 10, 2015, stating that the Commission staff had given the registration statement full review and setting forth staff comments. |
| (ii) | The Commission’s comments have been addressed in preparation of the Pre-Effective Amendment No. 2, filed on November 25, 2015. |
| (iii) | Securities reflecting changes described above will not be distributed until they are declared effective. |
We acknowledge that we are responsible for the accuracy and adequacy of the disclosure in the filing. We have provided all information investors require for an informed decision. Since the Separate Account and its management are in possession of all facts relating to the Separate Account’s disclosure, we are responsible for the accuracy and adequacy of the disclosures we have made.
We further acknowledge that:
| § | Should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; |
| § | The Registrant is responsible for the adequacy and accuracy of the disclosure in the filing; the staff's comments, the Registrant's changes to the disclosure in response to the staff's comments or the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrant from this responsibility; and |
| § | The Registrant may not assert this action or the staff's comments as defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
Thank you for your consideration and assistance. If you have any questions regarding this acceleration request or the Pre-Effective Amendment, please contact Tyler Schubauer, 402-325-4080.
Sincerely,
| On behalf of | On behalf of | |||
| Ameritas Variable Separate Account VA-2 | Ameritas Investment Corp. | |||
| /s/ Joanne M. Martin | /s/ Salene M. Hitchcock-Gear | |||
| Name: | JoAnn M. Martin | Name: | Salene M. Hitchcock-Gear | |
| Title: | Chair, President & Chief Executive Officer | Title: | President and Chief Executive Officer | |
| Ameritas Life Insurance Corp. | Ameritas Investment Corp. | |||