September 17, 2019


VIA E-MAIL

Max Berueffy, Esq.
Senior Counsel
Protective Life Insurance Company
P.O. Box 2606
Birmingham, AL 35202

           Re: Initial Registration Statement on Form N-6 for
               Protective Strategic Objectives VUL II
               Protective Life Insurance Company
               Protective Variable Life Separate Account
               File Nos. 333-232740 and 811-7337

Dear Mr. Berueffy:

        You filed the above-referenced initial registration statement on Form
N-6 on behalf of
Protective Life Insurance Company (the "Company") and its separate account on
July 19, 2019
(File No. 333-232740). Based on the representations in your letter dated July
23, 2019, we
conducted a selective review of the filing. See Securities Act Release No. 6510
(Feb. 15, 1984).
Based on our review, we have the following comments. 1

General

       1. Please confirm that all missing information, including the financial
statements and all
          exhibits, will be filed in a pre-effective amendment to the
registration statement. We may
          have further comments when you supply the omitted information.

       2. Please clarify supplementally whether there are any types of
guarantees or support
          agreements with third parties to support any policy features or
benefits, or whether the
          Company will be solely responsible for any benefits or features
associated with the
          Policies.




1
    Capitalized terms have the same meaning as in the registration statement
unless otherwise indicated.
 Max Berueffy, Esq.
September 17, 2019
Page 2 of 3

PROSPECTUS

Fee Tables (pp. 9-14)

   3. The "Transaction Fees" table indicates a current Transfer Fee charge.
This is inconsistent
      with footnote 2 and other disclosure in the prospectus that states that
the Company does
      not currently assess a transfer fee. Please reconcile.

   4. With respect to the "Net Cost of Loans" charge, please reflect the
Maximum Guaranteed
      charge for carryover loans.

   5. We note that the representative insured classification used for the cost
of the insurance
      charge and other periodic charges is different than the representative
insured
      classifications used for the Accidental Death Benefit Rider, the
Disability Benefit Rider,
      Protected Insurability Benefit Rider and the Extended Care Rider,. Please
supplementally
      explain the reason for the difference or revise the tables to use the
same representative
      insured classification.

   6. Please confirm supplementally that there are no premium taxes assessed
under the Policy.
      If there are such fees, add the line item to the table as required by
Item 3, Instruction 1(c),
      and add disclosure later per Item 5 of Form N-6.


Loan Repayment (p. 28)

   7. Please explain why the rate of interest to be credited to the Loan
Account will not be
      determined in advance of each calendar year. When will the rate be
determined and when
      will policy holders get notice of a new rate? Please specify.

Part C-Exhibits

   1. We note that exhibit 99.7(A), reinsurance agreement, appears to have
redacted
      information. If you intend to file the agreement with redacted
information, please refer to
      the requirements set forth in the FAST Act Modernization and
Simplification of
      Regulation S-K, Investment Company Act Release No. 10618 (Mar. 20, 2019).
See Form
      N-6, Item 26(g), Instruction 3. Otherwise, the unredacted agreement
should be filed.

                                        ********
        Responses to this letter should be made in a letter to me filed on
Edgar and in the form of
pre-effective amendment filed pursuant to Rule 472 under the Securities Act.
Where no change
will be made in the filing in response to a comment, please indicate this fact
in the letter to us
and briefly state the basis for your position.

        You should review and comply with all applicable requirements of the
federal securities
laws in connection with the preparation and distribution of preliminary
prospectuses.
 Max Berueffy, Esq.
September 17, 2019
Page 3 of 3


        Although we have completed our initial review of the registration
statement, the filing
will be reviewed further after we receive your response. Therefore, we reserve
the right to
comment further on the registration statement and any amendments. After we have
resolved all
issues, the Company and its underwriter must request acceleration of the
effective date of the
registration statement.

        In closing, we remind you that the Company is responsible for the
accuracy and
adequacy of its disclosure in the registration statement, notwithstanding any
review, comments,
action, or absence of action by the staff.

        Should you have any questions prior to filing the pre-effective
amendment, please feel
free to contact me at 202-551-6922.

                                                                   Sincerely,

                                                                   /s/ Sally
Samuel

                                                                   Sally Samuel
                                                                   Branch Chief


cc:    William J. Kotapish, Esq., Assistant Director