March 10, 2006
VIA FACSIMILE AND U.S. MAIL

Michael Berenson, Esq.
Morgan, Lewis & Bockius LLP
1111 Pennsylvania Avenue, NW
Washington, DC 20004

Re:	Empire Fidelity Investments Variable Annuity Account A
Empire Fidelity Investments Life Insurance Company
Registration Statement on N-4
File Nos. 333-130942/811-06388


Dear Mr. Berenson:

	The staff reviewed the above-referenced initial registration
statement, filed with the Commission on January 10, 2006.  The
registration statement received a selective review, based on your
representation that the registration statement is substantially
similar to an existing registration statement on Form N-4 (File
No.
333-121017) ("Prior Filing").  The page numbers referenced in this
comment letter correspond to the page numbers of the red-lined
courtesy copy that you provided to us, which you indicated, was
marked against the Prior Filing dated July 27, 2005.  Based on our
review, we have the following comments.

1. Power of Attorney

      In accordance with Rule 483(b) under the Securities Act of
1933, as amended, exhibits for certain registration statements,
please provide a power of attorney that relates to this filing,
specifically.

2. Financial statements, exhibits, and other information

      Financial statements, exhibits, and other information not
included in this registration statement should be filed by pre-
effective amendment.

3. Tandy Comment

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the insurance company and its
management
are in possession of all facts relating to the insurance company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

      Notwithstanding our comments, in the event the insurance
company requests acceleration of the effective date of the pending
registration statement, it should furnish a letter, at the time of
such request, acknowledging that

* should the Commission or the staff, acting 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.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Investment Management in connection with our review of
your filing or in response to our comments on your filing.

      We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities.

      ********************************************************

      Responses to these comments should be made in a letter to me
filed over the EDGAR system and in a pre-effective amendment to
the
registration statement.  If you believe that you do not need to
amend
the registration statement in response to a comment; please
explain
your position in the letter.

      Although we have completed an initial review of the
registration statement, it will be reviewed further after our
comments are resolved.  Therefore, the staff reserves the right to
comment further on any pre-effective amendments to the
registration
statement.
After all issues have been resolved, the Registrant and its
underwriter must both request that the effective date of the
registration statement, as amended, be accelerated.

      If you have any questions, please call me at (202) 551-6758.
Additionally, copies of documents or letters filed on EDGAR may be
emailed to me at lamontr@sec.gov or transmitted by facsimile to
(202)
772-9285.  Mail or deliveries should include a reference to zip
code
20549-4644.


      Sincerely,



								Robert S. Lamont, Jr.
								Senior Counsel
								Office of Insurance
Products



Comments & Document Record

Registrant:		Empire Fidelity Investments Variable Annuity
Account A
File No.:		333-130942; 811-06388
Type of Filing:	N-4
Date Filed:		January 10, 2006


Document
Author
Date sent/rec`d
N-4
Registrant
01/10/06




Michael Berenson, Esq.
Morgan, Lewis & Bockius LLP
March 10, 2006
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