[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. 333-162506 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




                              
                                 Capital Brokerage Corporation
                                 6620 West Broad Street
                                 Building 2
                     LOGO        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. 333-162506 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