[Ameritas Life Insurance Corp. Logo]
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P.O. Box 81889 / Lincoln, NE 68501-1889
5900 O Street / Lincoln, NE 68510-2234
(402) 467-1122
March 9, 2012
[Via EDGAR and Overnight Mail]
Michelle Roberts, Senior Counsel
Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re: Ameritas Life Insurance Corp. ("Ameritas Life") and
Ameritas Variable Separate Account VA-2, 1940 Act No. 811-05192
OVERTURE Medley! Flexible Premium Deferred Variable Annuity,
1933 Act No. 333-142483
Post-Effective Amendment No. 14 on Form N-4 Pursuant to Rule 485(a)
Response to Commission Staff Comment
Dear Ms. Roberts:
This letter is in response to a Commission staff review comment received by
telephone on March 1, 2012, for the above-referenced amendment filed January 20,
2012. This comment is in addition to comments previously received on February
14, 2012, which we addressed in correspondence filed February 23, 2012.
Comment. Regarding the decision to discontinue an asset allocation model as
an option for policies in the active GLWB rider phase, you asked us to
confirm that the adviser rather than the insurance company determined the
default model.
Response: This is to confirm that, with regard to the default model
that will be applicable when an allocation model is discontinued,
Ameritas Investment Corp. obtains advice from Summit Investment
Advisors, Inc. (Summit) concerning the fund specific model
recommendations, and the hedging associated with the Guaranteed
Lifetime Withdrawal Benefits Rider. This includes advice concerning
which model should be the default model when a model has been
discontinued. In developing its recommendations, Summit may consult
with unaffiliated third parties to obtain information on asset
class-level allocation weightings and impact of the models on
insurance reserves. Ameritas Investment Corp. makes a determination
based on the advice it receives from Summit.
We acknowledge: that the separate account is responsible for the adequacy and
accuracy of the disclosure in the filings; staff comments or changes to
disclosure in response to staff comments in the filings reviewed by the staff do
not foreclose the Commission from taking any action with respect to the filing;
and the separate account may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the federal
securities laws of the United States.
If you have further questions or comments concerning this filing, please
telephone me at 402-467-7847. Thank you for your assistance.
Sincerely,
/s/ Ann D. Diers
Ann D. Diers
Vice President & Associate General Counsel, Variable Contracts & AIC