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4333 Edgewood Road NE |
Cedar Rapids, Iowa 52499 |
January 29, 2013
Ms. Ashley Vroman-Lee
Senior Counsel – Office of Insurance Products
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549-0506
Re: | Monumental Life Insurance Company |
| Vanguard Variable Annuity |
| Post-Effective Amendment No. 13 to Form N-4 Registration Statement (File No. 333-146328) |
Dear Ms. Vroman-Lee:
The above-referenced Post-Effective No. 13 filing was made on January 25, 2013 (accession number is 0001193125-13-024092) pursuant to paragraph (a) of Rule 485 under the Securities Act of 1933. Monumental is filing the Registration Statement in order to modify the Guaranteed Lifetime Withdrawal Benefit rider fee.
For your reference, we have included a copy of the Registration Statement’s prospectus and SAI along with black-lined copies against the prospectus and SAI filed with the last Post-Effective Amendment No. 12, which filed on April 27, 2012.
We hereby request Selective Review pursuant to SEC Release No.: 33-6510 (February 15, 1984) for the above-referenced Vanguard Variable Annuity product filing.
This letter will also be filed as a correspondence filing via EDGAR.
Very truly yours,
Monumental Life Insurance Company
/s/ Darin D. Smith
Darin D. Smith
Managing Assistant General Counsel
Enc.
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