Allianz Life Insurance Company of North America [allianz Logo]
STEWART GREGG
Senior Securities Counsel
Corporate Legal
5701 Golden Hills Drive
Minneapolis, MN 55416-1297
Telephone: 763-765-2913
Telefax: 763-765-6355
stewart.gregg@allianzlife.com
www.allianzlife.com
April 24, 2009
Ms. Sally Samuel
Office of Insurance Products
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-4644
Re: Allianz Life Insurance Company of North America
Allianz Life Variable Account B
Post Effective Amendment No. 16 to Registration Statement Nos. 333-139701
and 811-05618
Post Effective Amendment No. 9 to Registration Statement Nos. 333-145866
and 811-05618
Allianz Life Insurance Company of New York
Allianz Life Variable Account C
Post Effective Amendment No. 11 to Registration Statement Nos. 333-143195
and 811-05716
Dear Ms. Samuel:
On April 23, 2009 the above-referenced post-effective amendments were filed via
Edgar to reflect a change in the acceleration of the effective dates from April
27, 2009 to May 1, 2009. We are hereby requesting withdrawal of the above
mentioned filings under form type AW pursuant to Rule 477 and are requesting
acceleration of the effective date for each Registration to May 1, 2009.
The Company acknowledges that the staff's review does not foreclose the
Commission from taking any action with respect to the filing. The action of the
staff in reviewing the filing does not relieve the Registrant from its full
responsibility for the adequacy and accuracy of the disclosure in the filing.
The Company may not assert this action as a defense in any proceeding initiated
by the Commission or any person under the federal securities laws of the United
States.
Manually executed signature pages and consents have been executed prior to the
time of this electronic filing and will be retained by the Company for five
years. Please contact me with any questions or comments you may have concerning
the enclosed. I can be reached at the address listed above or at (763) 765-2913.
Sincerely,
Allianz Life Insurance Company of North America and
Allianz Life Insurance Company of New York
By: /s/ Stewart Gregg
---------------------------------
Stewart D. Gregg
Allianz Life Financial Services, LLC [Allianz Logo]
5701 Golden Hills Drive
Minneapolis, MN 55416-1297
STEWART GREGG
Vice President
Telephone: 763-765-2913
Telefax: 763-765-6355
stewart.gregg@allianzlife.com
www.allianzlife.com
April 24, 2009
Ms. Sally Samuel
Office of Insurance Products
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-4644
Re: Allianz Life Insurance Company of North America
Allianz Life Variable Account B
Post Effective Amendment No. 16 to Registration Statement Nos. 333-139701
and 811-05618
Post Effective Amendment No. 9 to Registration Statement Nos. 333-145866
and 811-05618
Allianz Life Insurance Company of New York
Allianz Life Variable Account C
Post Effective Amendment No. 11 to Registration Statement Nos. 333-143195
and 811-05716
Dear Ms. Samuel:
Allianz Life Financial Services, LLC, as principal underwriter for the
above-referenced Registrants, joins the Registrants in their request to change
the effective date requested from April 27, 2009 to May 1, 2009.
The Registrant acknowledges that should the Commission or the staff, acting
pursuant to delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing. The
action of the Commission or the staff, acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the Registrant from its full
responsibility for the adequacy and accuracy of the disclosure in the filing.
The Registrant may not assert this action as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.
Sincerely,
Allianz Life Financial Services, LLC
/s/ Stewart Gregg
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Stewart D. Gregg
Vice President