October 14, 2020
Yoon Choo
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 Admiral VUL Flexible Premium Life Insurance Policy (333-238780) funded by Pacific Select Exec Separate Account (811-05563), 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 October 19, 2020, or as soon thereafter as practicable.
| Sincerely, | |
|
| |
| PACIFIC SELECT EXEC SEPARATE ACCOUNT OF PACIFIC LIFE INSURANCE COMPANY | |
|
| |
|
| |
| By: | /s/ Brandon J. Cage |
|
| Brandon J. Cage |
|
| Assistant Vice President, Counsel |
|
| |
|
| |
| PACIFIC SELECT DISTRIBUTORS, LLC | |
|
| |
|
| |
| By: | /s/ Christine Tucker |
|
| Christine Tucker |
|
| Chief Executive Officer |