Principal Life Insurance Co Separate Account B
Filed: 27 Apr 11, 12:00am
| April 27, 2011 | ||
| VIA EDGAR | ||
| Ms. Alison White | ||
| Senior Counsel | ||
| Office of Insurance Products | ||
| Division of Investment Management | ||
| Securities and Exchange Commission | ||
| 100 F Street, NE | ||
| Washington, D.C. 20549-4644 | ||
| RE: | Principal Life Insurance Company Separate Account B (the “Registrant”) | |
| Principal Life Insurance Company (the “Company”) | ||
| Principal Lifetime Income SolutionsSM- Variable Annuity | ||
| Pre-Effective Amendment No. 2 to Registration Statement filed on Form N-4 | ||
| File Nos. 333-171650 and 811-02091 | ||
| Dear Ms. White: | ||
| Pursuant to Rule 461 under the Securities Act of 1933 (the “Act”), Principal Life Insurance Company, on | ||
| behalf of itself and Principal Life Insurance Company Separate Account B, and Princor Financial | ||
| Services Corporation, the principal underwriter, hereby request acceleration of the effective date of pre- | ||
| effective amendment no. 2 to the registration statement electronically filed via Edgar on Form N-4 (File | ||
| Nos. 333-171650 and 811-02091) to May 2, 2011, or as soon thereafter as practicable. | ||
| Principal Life Insurance Company acknowledges the following: | ||
| · | should the Commission or the staff pursuant to delegated authority, declare the filing effective, it | |
| does not foreclose the Commission from taking any action with respect to the filing; | ||
| · | the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the | |
| filing effective, does not relieve the insurance company from its full responsibility for the | ||
| adequacy and accuracy of the disclosure in the filing; and | ||
| · | the insurance company may not assert this action as defense in any proceeding initiated by the | |
| Commission or any person under the federal securities laws of the United States. | ||
| Please contact Jeffrey M. Pierick at (515) 362-2384 if you have any questions regarding this request. | ||
| Sincerely, | ||
| /s/ Michael D. Roughton | /s/ Jeffrey M. Pierick | |
| Michael D. Roughton | Jeffrey M. Pierick | |
| Vice President and Associate General Counsel | Counsel | |
| Principal Life Insurance Company | Princor Financial Services Corporation | |