PHL Variable Insurance Company
One American Row Hartford, CT 06102-5056
(860) 403-6625 Fax: (860 403-7203
Email: Kathleen.McGah.@phoenixwm.com
January 14, 2015
VIA EDGAR and EMAIL
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-4644
Attention: Ms. Alison White, Senior Counsel
Division of Investment Management
| Re: | Withdrawal of Post-Effective Amendments on Forms N-4 and N-6, Filed on November 18, 2014 (Filing Date – November 19, 2014) |
PHL Variable Accumulation Account | ||
PHL Variable Insurance Company | ||
File No. 811-08914 | ||
Post-Effective Amendment No. 44 on Form N-4 | ||
The Big Edge Choice ® | File No. 033-87376, Version A | |
Phoenix Spectrum Edge ® | File No. 033-87376, Version C | |
Phoenix Spectrum Edge ® + | File No. 033-87376, Version D | |
Post-Effective Amendment No.16 on Form N-4 | ||
Phoenix Dimensions ® | File No. 333-123040 | |
PHLVIC Variable Universal Life Account | ||
PHL Variable Insurance Company | ||
File No. 811-09065 | ||
Post-Effective Amendment No. 7 on Form N-6 | ||
Phoenix Benefit Choice VUL ® | File No. 333-143656 | |
Post-Effective Amendment No. 4 on Form N-6 | ||
Phoenix Joint Edge ® VUL | File No. 333-149105 | |
Dear Ms. White:
In accordance with Rule 477 promulgated under the Securities Act of 1933, as amended, PHL Variable Insurance Company (the “Company”) hereby respectfully requests, on behalf of PHL Variable Accumulation Account and PHLVIC Variable Universal Life Account (together, the “Registrants”), that the Securities and Exchange Commission (the “Commission”) consent to the withdrawal of the Company’s above-referenced
post-effective amendments to its Form N-4 and N-6 registration statements (“the Post-Effective Amendments”), effective as of January 18, 2015.
Each of the Post-Effective Amendments will go effective automatically on January 18, 2015. The Company has elected not to proceed with the offerings related to the Post-Effective Amendments due to the Company’s inability to complete and file additional
Rule 485(b) post-effective amendments with the Commission by December 31, 2014 containing all the required information.
In making this request for withdrawal, the Company and the Registrants confirm that:
| • | the Post-Effective Amendments have not automatically become effective nor have they been declared effective by the Commission; |
| • | no securities have been sold in reliance on the Post-Effective Amendments or pursuant to the prospectuses contained therein; and |
| • | no preliminary prospectus contained in any of the Post-Effective Amendments has been distributed. |
The Company believes withdrawal of the Post-Effective Amendments is consistent with the public interest and the protection of investors.
The Company believes that it will complete and file with the Commission registration statements for the Registrants that include the Company’s financial statements for the year ended December 31, 2014 prepared in accordance with generally accepted accounting principles in the United States by April 30, 2015.
If there are any questions, please feel free to contact Kathleen A. McGah, Counsel, at 860-403-6625.
Sincerely,
/s/ Kathleen A. McGah
Kathleen A. McGah, Esq.
Vice President and Assistant Secretary
PHL Variable Insurance Company
cc: Lois McGuire
