August 24, 2007

VIA FACSIMILE AND EDGAR

The United States Securities
 and Exchange Commission
Division of Investment Management
Washington, DC 20549-0506

Attention: Mr. William Kotapish

Re:  Genworth Life Insurance Company of New York
     Pre-Effective Amendment No. 1 to
      Registration Statement filed on Form N-4
     File Nos. 333-143408 and 811-08475

Dear Mr. Kotapish:

Pursuant to Rule 461 under the Securities Act of 1933, Genworth Life Insurance
Company of New York (the "Company"), respectfully requests acceleration of the
effective date of the above-referenced Registration Statement to the earliest
date practicable after the filing of the Pre-Effective Amendment, but no later
than September 4, 2007.

We acknowledge 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
      Company from its full responsibility for the adequacy and accuracy of the
      disclosure in the filing; and

  .   the Company may not assert the declaration of effectiveness as a defense
      in any proceeding initiated by the Commission or any person under the
      federal securities laws of the United States.



Mr. William Kotapish
The United States Securities
 and Exchange Commission

Page 2



The undersigned is a Vice President of the Company and is duly authorized to
request accelerated effectiveness of the Registration Statement.

Please contact Michael Pappas at (804) 289-3545 if you have any questions
regarding this filing.


Sincerely,

/s/ Matthew P. Sharpe

Matthew P. Sharpe
Vice President
Genworth Life Insurance Company of New York


Cc:  Mr. Mark A. Cowan
     The United States Securities
      and Exchange Commission



August 24, 2007

VIA FACSIMILE AND EDGAR

The United States Securities
 and Exchange Commission
Division of Investment Management
Washington, DC 20549-0506

Attention: Mr. William Kotapish

Re:  Genworth Life Insurance Company of New York
     Pre-Effective Amendment No. 1 to
      Registration Statement filed on Form N-4
     File Nos. 333-143408 and 811-08475

Dear Mr. Kotapish:

Pursuant to Rule 461 under the Securities Act of 1933, Capital Brokerage
Corporation, the principal underwriter of the Flexible Purchase Payment
Variable Deferred Annuity Contracts to be issued by Genworth Life Insurance
Company of New York, respectfully requests acceleration of the effective date
of the above-referenced Registration Statement to the earliest date practicable
after the filing of the Pre-Effective Amendment, but no later than September 4,
2007.

The undersigned is a Senior Vice President of Capital Brokerage Corporation and
is duly authorized to request accelerated effectiveness of the Registration
Statement.

Please contact Michael Pappas at (804) 289-3545 if you have any questions
regarding this filing.

Sincerely,

/s/ Scott E. Wolfe

Scott E. Wolfe
Senior Vice President
Capital Brokerage Corporation

Cc:  Mr. Mark A. Cowan
     United States Securities
     and Exchange Commission