Minnesota Life Minnesota Life Insurance Company A Securian Financial Group Affiliate 400 Robert Street North St. Paul, MN 55101-2098 651.665.3455 Tel Robert L. Senkler Chairman and CEO December 17, 2014 Securities and Exchange Commission Office of Insurance Products 100 F Street, NE Washington, D.C. 20549-4644 Attn: Mr. Alberto Zapata Re: Minnesota Life Insurance Company Minnesota Life Individual Variable Universal Life Policy File Numbers 333-198279 and 811-22093 Dear Sir or Madam: It is requested that the above-referenced Registration Statement, as filed and amended by the above-referenced separate account of Minnesota Life Insurance Company on Form N-6, be declared effective December 19, 2014, or as soon thereafter as is practicable. Sincerely, /s/ Robert L. Senkler Robert L. Senkler RLS:tmy Securian George I. Connolly President and CEO December 17, 2014 Securities and Exchange Commission Office of Insurance Products 100 F Street, NE Washington, D.C. 20549-4644 Attn: Mr. Alberto Zapata Re: Minnesota Life Insurance Company Minnesota Life Individual Variable Universal Life Policy File Numbers 333-198279 and 811-22093 Dear Sir or Madam: On behalf of the principal underwriter of the above-referenced separate account of Minnesota Life Insurance Company, it is requested that the above-referenced Registration Statement, as filed and amended by said separate account on Form N-6, be declared effective December 19, 2014 or as soon thereafter as is practicable. Sincerely, /s/ George I. Connolly George I. Connolly President and CEO GIC:tmy Securian Financial Services, Inc. 400 Robert Street North St. Paul, MN 55101-2098 1.888.237.1838 Registered Investment Advisor Securities Dealer, Member NASD/SIPC