Dykema Gossett PLLC
Franklin Square, Third Floor West
[LOGO OF DYKEMA] 1300 I Street N.W.
Washington, DC 20005
WWW.DYKEMA.COM
Tel: (202) 906-8600
Fax: (202) 906-8669
HEATHER C. HARKER
Direct Dial: (202) 906-8649
Email: HHARKER@DYKEMA.COM
March 8, 2010
VIA EDGAR
The United States Securities and
Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Genworth Life and Annuity Insurance Company
Post-Effective Amendment No. 2 Under the Securities Act of 1933
File No. 333-143494
Dear Ladies and Gentlemen:
On behalf of Genworth Life and Annuity Insurance Company (the "Company"), we
hereby submit for filing in accordance with Regulation S-T concerning electronic
filing procedures Post-Effective Amendment No. 2 under the Securities Act of
1933 to the above-referenced Registration Statement on Form S-1 (the
"Post-Effective Amendment").
The purpose of the Post-Effective Amendment is to add two new strategists and to
wall-off existing strategists to new Certificates issued on or after September
1, 2010. The Company intends to file a subsequent Post-Effective Amendment to
the Registration Statement as soon as audited financial statements for the
Company are available.
The original, manually executed version of the Post-Effective Amendment and any
exhibits thereto will be maintained on file with the Company.
Should you have any questions, please contact me at 202.906.8649 or Mr. Michael
Pappas, Associate General Counsel - Genworth Life and Annuity Insurance Company
at 804.289.3545.
Sincerely,
DYKEMA GOSSETT PLLC
/S/ HEATHER C. HARKER
-----------------------------
HEATHER C. HARKER
CC: Michael D. Pappas
Genworth Life and Annuity Insurance Company