 | Administrative Office: 4333 Edgewood Road NE Cedar Rapids, IA 52499 | |||
January 15, 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: | Transamerica Life Insurance Company |
Separate Account VA B
Initial Filing to Form N-4 Registration Statement (File No. 333-186032)
Transamerica Financial Life Insurance Company
Separate Account VA BNY
Initial Filing to Form N-4 Registration Statement (File No. 333-186036)
Dear Ms. Vroman-Lee:
The above-referenced initial filings were made on January 15, 2013 (accession number is 0001193125-13-012770 and 0001193125-13-012807, respectively).Enclosed is a courtesy copy of theIncome Elite II prospectus and SAI (filed in both Separate Account VA B and Separate Account VA BNY).The Income Elite II variable annuity is essentially the same as the Transamerica Variable Annuity Series except it is a single share class, which is currently under review (accession number is 0001193125-12-509722 and 0001193125-12-509729, respectively). Besides removing the other share classes, we have made a few additional changes:
| • | different separate account annual expense fees; |
| • | fewer GMDBs; |
| • | fewer riders; and |
| • | different funds. |
We have included for your convenience a black-line against the Transamerica Variable Annuity Series prospectus and SAI.
We hereby request Selective Review pursuant to SEC Release No.: 33-6510 (February 15, 1984) for the above-referenced Income Elite II product filing.
This letter will also be filed as a correspondence filing via EDGAR.
Very truly yours,
Transamerica Life Insurance Company
Transamerica Financial Life Insurance Company
/s/ Darin D. Smith
Darin D. Smith
Managing Assistant General Counsel
Enc.
