April 6, 2016



Securities and Exchange Commission 					VIA EDGAR
Division of Investment Management
Office of Insurance Products
100 F Street NE
Washington, DC 20549-4644


Re: 	Minnesota Life Insurance Company
       Minnesota Life Variable Life Account
       File Number:  33-96383 and 811-4585

Dear Commissioners:
On behalf of Minnesota Life Insurance Company (the "Company") and Minnesota
Life Variable Life Account, we are filing this letter as correspondence to the
Form N-6 registration statement referenced above (the "Registration
Statement").  The letter responds to verbal comments received by the Company
from the staff of the Securities and Exchange Commission ("SEC") on March 30,
2016 and provides supplemental information regarding changes the Company is
making to the Variable Adjustable Life- Horizon Insurance Policy (the
"Policy") described in the prospectus to the Registration Statement.  Those
changes will be disclosed in a prospectus included in post-effective amendment
No. 24 to the Registration Statement.

1.	Exchange Offer (p. 35).   Please provide information supplementally
regarding how many policy owners are eligible for the exchange offer.

Response:

As of March 31, 2016, there are approximately 5,900 Policy owners that
have held the Policy for the requisite ten year period to qualify for the
proposed exchange.  However, some of those Policy owners may have had a
premium increase in the last three years and would need to wait until the
expiration of the three year period in order to be eligible for the
proposed exchange.

2.	Please provide supplementally any exchange offer letters, marketing
materials or other information, if available, that policy owners will
receive regarding the exchange offer.

Response:
The Company has not yet prepared exchange offer letters, marketing
materials or other information pieces because it was waiting to receive
comments from the SEC Office of Chief Counsel regarding its application.
The Company determined that it would be more efficient to prepare those
materials incorporating any comments received from the SEC.  In the event
the Office of Chief Counsel requests such materials regarding the exchange
offer, the Company will make them available via supplementary
correspondence.


3.	Exchange offer (p. 35).  The second paragraph in the section describing
the proposed exchange offer describes the types of eligible policy owners
that the offer will be made available to.  To that end, romanette i) and
ii) appear to be inconsistent and are confusing.  Please review and revise
to ensure that the terms are consistent.

Response:

The second paragraph describing the proposed exchange offer is missing a
word when it describes which Policy owners will be eligible to take
advantage of the offer.  Romanette ii) should state that the offer will
not be available to Policy owners "whose Policy was not subject to a
premium increase during the prior three years."  The prospectus language
will be revised to include the word "prior".


*   *   *   *   *   *   *

The Company believes that the changes noted above satisfy all of the SEC
staff's comments.  When the Company receives notice from the SEC Staff that
it should proceed with the filing of its pre-effective amendment, all of the
above proposed changes will be incorporated into post-effective amendment No.
24 to the Registration Statement.  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

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