November 22, 2019
Mark Cowan
Senior Counsel
Office of Insurance Products
Division of Investment Management
U.S Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-0506
RE: Registration Statement for Pacific KeyExec VUL Flexible Premium Life Insurance Policy (333-233112) funded by Pacific Select Exec Separate Account (File Number 811-05563) of Pacific Life Insurance Company, Request for Acceleration
Pursuant to Rule 461 under the Securities Act of 1933, we hereby request on behalf of Pacific Life Insurance Company and Pacific Select Distributors, LLC (collectively “Registrants”), acceleration of the effective date of the above referenced Registration Statement to November 29, 2019, or as soon thereafter as practicable.
| Sincerely, | |
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| PACIFIC SELECT EXEC SEPARATE ACCOUNT OF PACIFIC LIFE INSURANCE COMPANY | |
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| By: | /s/ Brandon J. Cage |
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| Brandon J. Cage |
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| Assistant Vice President, Counsel |
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| PACIFIC SELECT DISTRIBUTORS, LLC | |
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| By: | /s/ Christopher van Mierlo |
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| Christopher van Mierlo |
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| Chief Executive Officer |