November 10, 2016
VIA EDGAR
Ms. Kathryn M. Hinke
Attorney-Adviser
Disclosure Review and Accounting Office
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Registration Withdrawal Request |
FS Variable Separate Account (“Registrant”)
The United States Life Insurance Company in the City of New York (“Depositor”)
Polaris Advisory Variable Annuity
Form N-4, File Nos. 333-213342 and 811-08810
SEC Accession No. 0001193125-16-693886
EDGAR Submission Type RW
Dear Ms. Hinke:
Pursuant to Rule 477 of the Securities Act of 1933, as amended, FS Variable Separate Account (“the Registrant”), a separate account of The United States Life Insurance Company in the City of New York, hereby requests the withdrawal of Registrant’s initial registration statement (the “Registration Statement”) onForm N-4 for the Polaris Advisory Variable Annuity, SECFile Nos. 333-213342 and811-08810, filed with the Securities and Exchange Commission on August 26, 2016.
The Registration Statement has not been declared effective. The Registrant has determined not to proceed with the registration and sale of the securities covered by the Registration Statement. No securities were sold in connection with the offering. Accordingly, we request that the Commission grant an order for the withdrawal of the Registration Statement and declare the withdrawal effective upon filing.
Sincerely,
/s/ Helena Lee
Helena Lee
Assistant General Counsel
