[GENWORTH LIFE INSURANCE COMPANY OF NEW YORK LETTERHEAD]




December 30, 2009

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. 333-162504 and 811-22339

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 any date on or
after January 4, 2010, but no later than January 19, 2010.

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/ Michael P. Cogswell
--------------------------
Michael P. Cogswell
Vice President
Genworth Life Insurance Company of New York



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





     
 LOGO   Capital Brokerage Corporation
        6620 West Broad Street
        Building 2
        Richmond, VA 23230



December 30, 2009

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. 333-162504 and 811-22339

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 any date on or after
January 4, 2010, but no later than January 19, 2010.

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



               Capital Brokerage Corporation - Member FINRA/SIPC