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 | | Administrative Office: 4333 Edgewood Road NE Cedar Rapids, IA 52499 |
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May 15, 2013
Mr. Michael Kosoff
Insured Investments Office
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549
| Re: | Transamerica Advisors Life Insurance Company |
| | Form S-3 Pre-Effective Amendment No. 2 |
Dear Mr. Kosoff:
This letter responds to comments that you provided with respect to the Pre-Effective Amendment No. 2 of the above-referenced registration statement on Form S-3 of Transamerica Advisors Life Insurance Company (“TALIC” or “we”). For your convenience, I have restated your comments below, and followed each comment with our response.
Comments:
1. | Fee Table –Please clarify that the dash means that the option is not available. |
Response:We have added NA in the Fee Table rather than dashes.
2. | Fee Table –Please note that the fees can increase up to the maximum somewhere in the Fee Table as well as stating it on page 60 . |
Response:We have complied with the comment.Please see page 6.
3. | Website –Please confirm that the investor website will be up and running prior to the product launching. |
Response:The investor website will be available prior to launch.
Very truly yours,
/s/ Darin D. Smith
Darin D. Smith
Managing Assistant General Counsel
Enclosures
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