MAX BERUEFFY
Senior Associate Counsel
Writer’s Direct Number: (205) 268-3581
Facsimile Number: (205) 268-3597
Toll-Free Number: (800) 627-0220
February 14, 2014
VIA EDGAR AND E-MAIL
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: | Protective Life Insurance Company |
| Protective Variable Annuity Separate Account, No. 811-8108 |
| Protective Dimension, No. 333-176657 |
| Post-Effective Amendment No. 8 to Registration Statement on Form N-4 |
Commissioners:
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 “Securities Act”), the Investment Company Act of 1940, and Rule 101(a) of Regulation S-T, a conformed electronic format copy of Post-Effective Amendment No. 8 to the Form N-4 registration statement for certain variable annuity contracts (“Protective Dimensions”) being issued through the Account.
This Post-Effective Amendment is being filed pursuant to Rule 485(a) under the Securities Act of 1933 to describe a revised version of Protective Dimensions and its SecurePay benefit effective May 1, 2014.
If you have any questions, or require any additional information, please contact me at 205.268.3581. You may also contact Elisabeth Bentzinger with Sutherland Asbill & Brennan at 202.383.0717. We thank you for your assistance with this filing.
| Very truly yours, |
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| /s/ Max Berueffy |
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| Max Berueffy |
Cc: | Elisabeth Bentzinger, Esq. |
| Sutherland Asbill & Brennan |