Protective Variable Annuity Separate Account
Filed: 4 Mar 09, 12:00am
MAX BERUEFFY
Senior Associate Counsel
Writer’s Direct Number: (205) 268-3581
Facsimile Number: (205) 268-3597
Toll-Free Number: (800) 627-0220
| March 4, 2009 |
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Craig Ruckman
Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
RE: |
| Protective Life Insurance Company |
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| Protective Variable Annuity Separate Account |
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| File Nos. 811-8108 and 333-112892 |
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Mr. Ruckman:
On behalf of Protective Life Insurance Company (“the Company”) and Protective Variable Annuity Separate Account (the “Account”), we are transmitting for filing with the Commission pursuant to the Securities Act of 1933, the Investment Company Act of 1940, and Rule 101(a) of Regulation S-T, a conformed electronic format copy of Post-Effective Amendment No. 10 to the Form N-4 registration statement for certain variable annuity contracts (“ProtectiveValues”) being issued through the Account.
This Post-Effective Amendment is being filed pursuant to Rule 485(a) under the Securities Act of 1933 to modify the optional guaranteed living withdrawal benefit (“SecurePay”) offered under the contract, and to eliminate certain features and add others associated with the current SecurePay benefit.
I also enclose a copy of our letter to William J. Kotapish, Assistant Director, Office of Insurance Products, requesting “template” treatment in connection with this Post-Effective Amendment, as well as a copy of our letter asking that we be allowed to amend our February 2, 2009, template request to extend the “template” relief described therein to post-effective amendment number 11 to the ProtectiveValues variable annuity registration statement, since we have now filed post-effective amendment number 10 to make other changes to the ProtectiveValues registration.
If you have any questions or comments regarding this registration statement, please call the undersigned at (800) 627-0220.
| Sincerely, |
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| /s/ Max Berueffy |
| Max Berueffy |
| Senior Associate Counsel |
Cc: Ms. Elisabeth Bentzinger