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VIA EDGAR AND ELECTRONIC MAIL

January 18, 2012

Mr. Jeffrey Foor
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Re:      Variable Separate Account ("Registrant")
         SunAmerica Annuity and Life Assurance Company ("Depositor")
         Post-Effective Amendment to Registration Statement on Form N-4
         File Nos. 333-172003 and 811-03859

Dear Mr. Foor:

         Thank you for the additional comment regarding the Post-Effective
Amendment to the Registration Statement on Form N-4 filed pursuant to Rule
485(a) on November 2, 2011 as referenced above. We have considered the comment
and provided our response below.

     1.  Fees, pages 7 and 33

              Comment -- Please add additional disclosure regarding the effects
              of higher volatility markets on both living benefit fees and the
              exposure of investments in the SunAmerica Dynamic Allocation
              Portfolio to equity markets.

                  Response -- The following disclosure has been added to
                  footnote 7 of the fee table on page 7 as a separate paragraph
                  and under "What is the fee for SunAmerica Income Plus and
                  SunAmerica Income Builder" on page 33 of the prospectus:

                  "Due to the investment requirements associated with the
                  election of a living benefit, a portion of your assets may be
                  invested in the SunAmerica Dynamic Allocation Portfolio. The
                  SunAmerica Dynamic Allocation Portfolio utilizes an investment
                  strategy that is intended, in part, to maintain a relatively
                  stable exposure to equity market volatility over time.
                  Accordingly, when the market is in a prolonged state of higher
                  volatility, your fee rate may be increased and the SunAmerica
                  Dynamic Allocation Portfolio may decrease its exposure to
                  equity markets, thereby reducing the likelihood that you will
                  achieve a higher Anniversary Value. Similarly, when the market
                  is in a prolonged state of lower volatility, your fee rate may
                  be decreased and the SunAmerica Dynamic Allocation Portfolio
                  may increase its exposure to equity markets."

As previously communicated, we plan to make 485(b) filings to incorporate the
Staff's comments as well as financial statements of the Depositor and Registrant
on January 20, 2012. We appreciate your assistance. If you have any questions or
comments, please call me at 310-772-6545.

Very truly yours,

/s/ Manda Ghaferi

Manda Ghaferi
Assistant General Counsel