February 24, 2017 VIA EDGAR Ms. Kathryn M. Hinke Attorney-Adviser Disclosure Review and Accounting Office U.S. Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Registration Withdrawal Request FS Variable Separate Account ("Registrant") The United States Life Insurance Company in the City of New York ("Depositor") Polaris Advisory Variable Annuity (Version C) Form N-4, File Nos. 333-213907 and 811-08810 SEC Accession No. 0001193125-16-727698 EDGAR Submission Type RW Dear Ms. Hinke: Pursuant to Rule 477 of the Securities Act of 1933, as amended, FS Variable Separate Account ("the Registrant"), a separate account of The United States Life Insurance Company in the City of New York, hereby requests the withdrawal of Registrant's initial registration statement (the "Registration Statement") on Form N-4 for the Polaris Advisory Variable Annuity (Version C), SEC File Nos. 333-213907 and 811-08810, filed with the Securities and Exchange Commission on September 30, 2016. The Registration Statement has not been declared effective. The Registrant has determined not to proceed with the registration and sale of the securities covered by the Registration Statement. No securities were sold in connection with the offering. Accordingly, we request that the Commission grant an order for the withdrawal of the Registration Statement and declare the withdrawal effective upon filing. Sincerely, /s/ Helena Lee Helena Lee Assistant General Counsel