Report of Independent Registered Public Accounting
Firm

To the Board of Directors of Transamerica Financial Life
Insurance Company and Contract holders of Transamerica
Asset Allocation Variable Funds:

In planning and performing our audits of the financial
statements of Transamerica Asset Allocation Variable
Funds (the "Trust") (comprising, respectively,
Transamerica Asset Allocation - Short Horizon
Subaccount, Transamerica Asset Allocation - Intermediate
Horizon Subaccount and Transamerica Asset Allocation -
Intermediate/Long Horizon Subaccount) (collectively, the
"Subaccounts") as of and for the year ended December 31,
2018, in accordance with the standards of the Public
Company Accounting Oversight Board (United States), we
considered the Trust's internal control over financial
reporting, including controls over safeguarding securities,
as a basis for designing our auditing procedures for the
purpose of expressing our opinion on the financial
statements and to comply with the requirements of Form N-
CEN, but not for the purpose of expressing an opinion on
the effectiveness of the Trust's internal control over
financial reporting. Accordingly, we express no such
opinion.

The management of the Trust is responsible for establishing
and maintaining effective internal control over financial
reporting. In fulfilling this responsibility, estimates and
judgments by management are required to assess the
expected benefits and related costs of controls. A
company's internal control over financial reporting is a
process designed to provide reasonable assurance regarding
the reliability of financial reporting and the preparation of
financial statements for external purposes in accordance
with U.S. generally accepted accounting principles. A
company's internal control over financial reporting
includes those policies and procedures that (1) pertain to
the maintenance of records that, in reasonable detail,
accurately and fairly reflect the transactions and
dispositions of the assets of the company; (2) provide
reasonable assurance that transactions are recorded as
necessary to permit preparation of financial statements in
accordance with U.S. generally accepted accounting
principles, and that receipts and expenditures of the
company are being made only in accordance with
authorizations of management and directors of the
company; and (3) provide reasonable assurance regarding
prevention or timely detection of unauthorized acquisition,
use or disposition of a company's assets that could have a
material effect on the financial statements.

Because of its inherent limitations, internal control over
financial reporting may not prevent or detect
misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk that
controls may become inadequate because of changes in
conditions, or that the degree of compliance with the
policies or procedures may deteriorate.

A deficiency in internal control over financial reporting
exists when the design or operation of a control does not
allow management or employees, in the normal course of
performing their assigned functions, to prevent or detect
misstatements on a timely basis. A material weakness is a
deficiency, or a combination of deficiencies, in internal
control over financial reporting, such that there is a
reasonable possibility that a material misstatement of the
company's annual or interim financial statements will not
be prevented or detected on a timely basis.
Our consideration of the Trust's internal control over
financial reporting was for the limited purpose described in
the first paragraph and would not necessarily disclose all
deficiencies in internal control that might be material
weaknesses under standards established by the Public
Company Accounting Oversight Board (United States).
However, we noted no deficiencies in the Trust's internal
control over financial reporting and its operation, including
controls over safeguarding securities that we consider to be
a material weakness as defined above as of December 31,
2018.

This report is intended solely for the information and use of
management and the Board of Trustees of the Trust and the
Securities and Exchange Commission and is not intended to
be and should not be used by anyone other than these
specified parties.


/s/ Ernst & Young LLP

Boston, Massachusetts
February 26, 2019



Information Classification: Limited Access

Information Classification: Limited Access