 |
4333 Edgewood Road NE Cedar Rapids, Iowa 52499 |
June 16, 2011
Mr. Craig Ruckman
Staff Attorney – Office of Insurance Products
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549-0506
| Re: | Post-Effective Amendment No. 8 to the Registration Statement on Form N-4 for Monumental Life Insurance |
| Company, Separate Account VA DD (File No. 333-146328) (“Registration Statement”) |
Dear Mr. Ruckman:
The above-referenced Registration Statement was filed with the Securities and Exchange Commission by Monumental Life Insurance Company (“Monumental”) as Post-Effective Amendment No. 8 on June 15, 2011 pursuant to paragraph (a) of Rule 485 under the Securities Act of 1933.
For your reference, Monumental has included one copy of the Registration Statement’s prospectus along with a redlined prospectus to show the changes from Post-Effective Amendment No. 7, which was filed on April 25, 2011. Capitalized terms used and not otherwise defined are consistent with the defined terms set forth in the Registration Statement’s prospectus.
Monumental is filing the Registration Statement in order to add a Guaranteed Lifetime Withdrawal Benefit, modify the Return of Premium Death Benefit option, and update the fee table to exclude the Annual Step-Up Death Benefit option which is no longer available to new policies.
Except for the material revisions noted above and as shown in the red-lined copy of the prospectus, the disclosure in the Registration Statement is the same as the disclosure in the currently effective Registration Statement previously reviewed by the Commission. Monumental will also include other non-material changes in the Registration Statement. Therefore, pursuant to Investment Company Act Release No. 13768, Monumental respectfully requests selective review of the Registration Statement.
If you have any comments or questions regarding these filings, please call Alaina Thier at (319) 355-5591 or Shane Daly at (319) 355-8327.
Very truly yours,
/s/ Shane Daly
Shane Daly
Enclosures
| cc: | Craig Ruckman, Esq. |
