December 17, 2015
Ms. Sally Samuel
Branch Chief
Disclosure Review Office 3
Division of Investment Management
United States Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-0506
| Re: | Massachusetts Mutual Life Insurance Company |
| Massachusetts Mutual Variable Life Separate Account I |
| Strategic Group Variable Universal Life II (“GVUL II”) |
| Pre-Effective Amendment No. 2 on Form N-6 |
| File Nos. 333-206438 and 811-08075 |
Dear Ms. Samuel:
Thank you for your comment provided via telephone on December 16, 2015 regarding the above-referenced filing.
Pursuant to our discussion, we have revised the refund language in the second paragraph of the “Your Right to Return the Certificate” section of the prospectus to provide as follows:
The refund will equal any premium paid for this certificate plus interest credited to this certificate under the GPA to the date this certificate is received by us.
As we discussed, this language is appropriate given that, during the Free Look period, all premiums for all certificates are allocated to the Guaranteed Principal Account (GPA). I can confirm that even in states where only a refund of premium is required, we will refund premium plus any interest credited under the GPA. I have included a marked copy of the revised page in the prospectus that reflects this change.
We will incorporate this change into a Rule 497(c) filing that will be filed following the effectiveness of the above-referenced filing. Please call me at (413) 744-6240 or e-mail me atgmurtagh@massmutual.com if you have any questions regarding this letter or if you need any additional information.
Sincerely,
/s/ Gary F. Murtagh
Gary F. Murtagh
Vice President and Senior Counsel
Massachusetts Mutual Life Insurance Company