[Monumental Life Insurance Company Letterhead]
December 17, 2007
Craig Ruckman, Esq.
Office of Insurance Products
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549-0506
| Re: | Monumental Life Insurance Company |
Separate Account VA CC (Advisor’s Edge Variable Annuity)
File Nos. 333-146323; 811-06564
Dear Mr. Ruckman:
This letter responds to oral comments that you provided with respect to the above-referenced post-effective amendment filings for Separate Account VA CC of Monumental Life Insurance Company (“Monumental” or “we”). For your convenience, I have restated those comments below (as best we understand them), and followed each comment with our response. The comments apply to disclosure in both post-effective amendment filings.
Comments regardingFee Table andExpense Examples of prospectus supplements:
Comment #1. In the expense examples, specify whether showing current or maximum charges.
Response: The following italicized language has been added to Footnote 1 of the Fee Table.
(1) | The fee table applies only to the accumulation phase and reflects the maximum charges unless otherwise noted. During the income phase the fees may be different than those described in the Fee Table. See Section 5, Expenses. |
General comments on supplements:
Comment #2. Move examples in the supplements to the statement of additional information (“SAI”) to the prospectus supplements, potentially as appendices.
Response: We respectfully decline the removal of the examples from the SAI.
Comment #3. The section that describes the rider should not just summarize the rider, but should include all the material rights and obligations of the rider.
Response: We have revised our disclosure to read:
This disclosure explains the material features of the Architect GLWB. The application and operation of the Architect GLWB are governed by the terms and conditions of the rider itself. The Architect GLWB may vary for certain policies and may not be available for all policies.
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Do not hesitate to contact me at (319) 355-8427 with any comments or questions you have about any of the responses provided above.
Very truly yours,
| /s/ Sandy K. Dix |
| Sandy K. Dix |
| Manager, Registered Product and Distribution |
| Monumental Life Insurance Company |
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