November 9, 2000

Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C.  20549-10014


ATTN: Document Control - EDGAR


RE:      Pre-Effective Amendment No. 1 on Form S-6 (File No. 333-44644)
         And Amendment No. 7 to Form N-8B-2
         IDS Life of New York Account 8
         Investment Company Act No. 811-05213


Dear Commissioners:


IDS  Life of New  York  Account  8,  the  Registrant,  has  filed  Pre-Effective
Amendment  No. 1, dated on or about  November 9, 2000,  to the  above-referenced
Form S-6 Registration Statement. Pursuant to Rule 461, the Principal Underwriter
for the Registrant,  American Express  Financial  Advisors Inc. now respectfully
requests that the effective date of the Registration be accelerated and that the
Registration  Statement be declared effective on November 20, 2000 or as soon as
practicable thereafter.

Yours Truly,

AMERICAN EXPRESS FINANCIAL ADVISORS INC.
(Principal Underwriter)



/s/  Teresa J. Rasmussen
     Teresa J. Rasmussen
     Vice President and Managing Counsel