Separate Account Va BNY CORRESP Correspondence with SEC

Administrative Office: 4333 Edgewood Road NE Cedar Rapids, IA 52499

September 20, 2019

Mr. Mark Cowan

U.S. Securities and Exchange Commission

100 F Street NE

Washington, DC 20549-0506

Re: Transamerica Life Insurance Company

Separate Account VA B

Initial Filing to Form N-4 Registration Statement (File No. 333-233837)

Transamerica Financial Life Insurance Company

Separate Account VA BNY

Initial Filing to Form N-4 Registration Statement (File No. 333-233841)

Dear Mr. Cowan:

The above-referenced initial filings were made with the Securities and Exchange Commission by Transamerica Life Insurance Company and Transamerica Financial Life Insurance Company (“Transamerica”) on September 19, 2019 (“New Registration Statements”). The accession numbers are 0001193125-19-249123 for Separate Account VA B and 0001193125-19-249149 for Separate Account VA BNY.

Enclosed please find a courtesy copy of the Transamerica Axiom^SM III Variable Annuity prospectus and SAI (filed in both Separate Account VA B and Separate Account VA BNY).

The Transamerica Axiom^SM III Variable Annuity generally mirrors the Transamerica Axiom^SM II Variable Annuity (File No. 333-186029 (non-NY)/333-186033 (NY) (the “Current Registration Statements”)) with some slight modifications. Those modifications to the product are:

1. The Annual Service Charge is $35;

2. The M&E&A is lower;

3. The M&E&A upon annuitization is the same as in the deferred stage;

4. Transamerica Principal Optimizer^SM is being introduced as a new guaranteed living withdrawal benefit; and

5. Retirement Income Choice^® 1.7, Retirement Income Max^® 1.2 and Transamerica Income Edge^SM 1.2 are available as guaranteed living withdrawal benefits.

Except for the changes described above, the disclosure in the New Registration Statements are the same as the disclosure in the Current Registration Statements with regard to the Transamerica Axiom^SM II, which has been previously reviewed by the Commission. Therefore, pursuant to Investment Company Act Release No. 13768, Transamerica respectfully requests selective review of the changes noted in the items listed above contained in the New Registration Statements.

Mr. Mark Cowan

September 20, 2019

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If you have any comments or questions regarding the filing, please call Brian Stallworth at (720) 488-7884, or Becky Reddick at (319) 355-2747, with any comments or questions.

Sincerely,

/s/ Brian Stallworth

Brian Stallworth

Senior Counsel