<Page> June 15, 2009 VIA FACSIMILE AND EDGAR Securities and Exchange Commission 450 5th Street, NW Washington, DC 20549 Re: SEPARATE ACCOUNT A OF COMMONWEALTH ANNUITY AND LIFE INSURANCE COMPANY File Nos. 333-157121 and / 811-22024 Dear Sirs: The undersigned hereby request that the above captioned Registration Statement, including Pre-effective Amendment No. 1 thereto, be declared effective on July 1, 2009 or as soon thereafter as reasonably practicable. Separate Account A of Commonwealth Annuity and Life Insurance Company BY: /s/ Michael A. Reardon ----------------------- Michael A. Reardon President and CEO of Commonwealth Annuity and Life Insurance Company Commonwealth Annuity and Life Insurance Company BY: /s/ Michael A. Reardon ----------------------- Michael A. Reardon President and CEO Epoch Securities, Inc. (Principal Underwriter) BY: /s/ Michael A. Reardon ----------------------- Michael A. Reardon President