Transamerica Advisors Life Insurance Inactive
Filed: 30 Aug 13, 12:00am
 | Transamerica Advisors Life Insurance Company
Transamerica Advisors Life Insurance Company of New York
Administrative Office: 4333 Edgewood Road NE Cedar Rapids, IA 52499 |
August 30, 2013
Mr. Joel Parker
Accounting Branch Chief
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
| Re: | Transamerica Advisors Life Insurance Company |
Item 4.01 Form 8-K
Filed August 23, 2013
File No. 033-26322
Transamerica Advisors Life Insurance Company of New York
Item 4.01 Form 8-K
Filed August 23, 2013
File No. 033-34562
Dear Mr. Parker:
This letter responds to written comments that you provided with respect to the above-referenced 8-K Filings for Transamerica Advisors Life Insurance Company and Transamerica Advisors Life Insurance Company of New York (the “Companies”). For your convenience, I have restated those comments below, and followed each comment with our response.
| 1. | Please confirm that you will amend this Item 4.01 8-K to: |
| • | Disclose the effective date of the dismissal of Ernst & Young LLP once they have completed their audit services for the fiscal year ending December 31, 2013 and the filing of the Company’s 2013 annual report on Form 10-K; and |
| • | Update the interim period related to paragraphs (a)(1)(iv) and (a)(2) of Item 304 of Regulation S-K through the effective date of dismissal. |
RESPONSE:The Companies will disclose in amended 8-K filings:
| • | the dismissal of Ernst & Young LLP once they have completed their audit service for the fiscal year ending December 31, 2013 and filing of the Companies’ 2013 annual reports on Form 10-K; and |
| • | the Companies will also update the interim period related to paragraphs (a)(1)(iv) and (a)(2) of Item 304 of Regulation S-K through the effective date of dismissal. |
| 2. | Upon amending your filing, please include, as Exhibit 16, an updated letter from your former accountants, Ernst & Young LLP, addressing the revised 8-K disclosure, as required by Item 304(a)(3) of Regulation S-K. |
RESPONSE:The Companies will include in the amended 8-K filings an exhibit of the updated letter from Ernst & Young LLP, addressing the revised 8-K disclosure.
Mr. Joel Parker
U.S. Securities and Exchange Commission
August 30, 2013
Page 2
The Companies also acknowledge that:
| • | the Companies are responsible for the adequacy and accuracy of the disclosure in the filing; |
| • | staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filing; and |
| • | the Companies may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
I trust that the responses provided in this letter address your comments adequately. If you have any questions regarding these responses, please contact the undersigned at 319-355-8330. Thank you very much for your assistance with this filing.
| Sincerely, |
/s/ Darin D. Smith |
| Darin D. Smith |
| Associate General Counsel |
| Individual Savings & Retirement Division |
| Transamerica Advisors Life Insurance Company and |
| Transamerica Advisors Life Insurance Company of New York |
cc: Mr. Scott Wuenschell, Staff Accountant