Wyatt, Tarrant & Combs
                              2800 Citizens Plaza
                           Louisville, Kentucky 40202

                                                  June 23, 1995

Edward MacDonald
Securities and Exchange Commission
Judiciary Plaza
450 Fifth Street
Washington, D.C. 20549

Dear Mr. MacDonald:

     This letter relates to  Post-Effective  Amendment No. 1 to the Registration
Statement  on Form N-14 of Variable  Annuity  Fund I of  Southwestern  Life (the
"Separate Account") and Scudder Varible Life Investment Fund, File No. 33-59447,
that is being filed  electronically  today. The sole purpose of the amendment is
to amend the  signature  page that was  initially  filed  with the  registration
statement  on behalf of the  Separate  Account,  to conform  it to the  manually
signed  signature  page,  which was  executed  by and on behalf of the  Separate
Account in  accordance  with Rule 302 of  Regulation  S-T. The  manually  signed
signature  page was signed by three of the four members of the Board of Managers
of the Separate  Account,  but the electronic  filing only showed the names (and
signatures) of two of the four members of the Board.

     The  registrants  request that the  Commission  declare the  Post-Effective
Amendment No. 1 to the Registration Statement  automatically  effective pursuant
to Rule 485(b) (ix) of Regulation C.

                                             Sincerely yours,

                                             WYATT, TARRANT & COMBS

                                             Cynthia W. Young

CWY