June 19, 2015
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, Protective Life Insurance Company, on its own behalf and on behalf of ProtectiveVariable Annuity Separate Account, hereby requests that Pre-Effective Amendment No. 1 to the Registration Statement filed on Form N-4 (File No. 333-201921) be accelerated and declared effective on July, 20, 2015, or as soon thereafter as is reasonably practicable.
| Protective Life Insurance Company |
| |
| Protective Variable Annuity Separate Account |
| |
| | |
| By: | /s/ John D. Johns |
| | John D. Johns |
| | President and Chief Executive Officer |
INVESTMENT DISTRIBUTORS, INC.
2801 Highway 280 South · Birmingham, AL · 35223 · (205)268-1000
June 19, 2013
VIA EDGAR
U.S. Securities and Exchange Commission
100 F St., N.E.
Washington, D.C. 20549
Commissioners:
Pursuant to Rule 461 under the Securities Act of 1933, Investment Distributors, Inc., the principal underwriter, hereby requests that Pre-Effective Amendment No. 1 to the Registration Statement filed on Form N-4 (File No. 333-201921) be accelerated and declared effective on July 20, 2013, or as soon thereafter as is reasonably practicable.
| Investment Distributors, Inc. |
| | |
| By: | /s/ Edwin V. Caldwell |
| | Edwin V. Caldwell |
| | President |