October 29, 2014

Mr. Alberto Zapata
Securities and Exchange Commission
100 F Street, NE
Washington, D.C.  20549-4644

Re: Post-Effective Amendment No. 16 to the Form N-6 Registration Statement
filed on behalf of Minnesota Life Accumulator Individual Variable Universal
Life Account (File Numbers 333-148646 and 811-22093)

Dear Mr. Zapata:

This letter is in response to the SEC Staff comments received by the Company
in telephone conversations on October 24, 2014.  Below are responses to the
SEC Staff's oral comments.  For the SEC Staff's convenience, each of the SEC
Staff's comments is set forth below, and then the response follows.

* * * * * * * * *

Premium Deposit Account

1.   Please confirm that the addition of the Premium Deposit Account to the
Policy will not cause the Policy to become a modified endowment contract (MEC)
as defined under the Internal Revenue Code of 1986, as amended (IRC).  Has the
Company obtained an opinion of counsel as to the tax status of the Premium
Deposit Account?

Response:

The Company believes that the Premium Deposit Account Agreement will not cause
the Policy to become a MEC.  The Company pays annual interest on the balance in
the Premium Deposit Account, required tax testing occurs when premium is paid
on each Policy anniversary and the balance in the Account is not used to
support the Policy death benefit until it is transferred as premium on each
Policy Anniversary.

The Company reviews relevant tax law, tests for compliance with the IRC,
discusses tax matters with tax counsel and is comfortable with its
determination that the Premium Deposit Account complies with the IRC.

2. Please provide disclosure describing the impact on the Premium Deposit
Account when the Policy terminates as a result of the insured's death.

Response:

In response to the SEC Staff comment, the Company has added the following
disclosure as the sixth paragraph under the description of the Premium Deposit
Account Agreement:

If the insured dies while the Policy and the Premium Deposit Account are in
force, we will pay the Death Benefit payable under the Policy as well as any
remaining balance in the Premium Deposit Account. We will pay you interest on
that remaining balance, using the then current interest rate for the Premium
Deposit Account.   Interest will be credited from the date of your payment to
the Premium Deposit Account or if later, the date the last premium payment was
made from the Premium Deposit Account.

In addition, the Company has corrected a typographical error in the last
sentence of the fifth paragraph under the description of the Premium Deposit
Account.  The last sentence of the paragraph should read as follows:

Interest will be credited from the date of your payment to the Premium Deposit
Account or if later, the date the last premium payment was made from the
Premium Deposit Account.

A marked courtesy copy showing the changes to the prospectus supplement has
been forwarded to the SEC Staff.

* * * * * * * * *

The Company believes that the changes noted above satisfy all of the SEC
Staff's comments.  The Company plans to file its post-effective amendment to
incorporate the changes on November 21, 2014.  If there are additional
questions or comments, please contact the undersigned at (651) 665-4593.

Very truly yours,

/s/ Timothy E. wuestenhagen

Timothy E. Wuestenhagen
Senior Counsel


cc: 	Thomas E. Bisset, Esq.