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CORRESP

Trina Sandoval

Vice President and Deputy General Counsel

Corebridge Financial

T (213) 218-1918

21650 Oxnard Street, Suite 750

trina.sandoval@corebridgefinancial.com

Woodland Hills, CA 91367

 August 5, 2024

 Mr. Mark Cowan

Securities and Exchange Commission

 Division of Investment Management

100 F Street, N.E. Washington, D.C. 20549

 Re: American General Life Insurance
Company (the “Company”)

 Pre-Effective Amendment No. 1 to Registration Statement on Form S-1

 File No. 333-277203

Dear Mr. Cowan:

 Thank you for your verbal comments on July 12, 2024,
regarding the Pre-Effective Amendment No. 1 to Form S-1 registration statement referenced above. We have responded to your comments as follows:

General

1.
 Comment – While we are okay with the new novel crediting methodology, we noted that the company
intends to change the buffer on these new index options from one term to the next, and rather than including the buffer percentage in the prospectus, has disclosure stating that the current buffer rates can be found on the company website. It is the
staff’s position that all index option features other than current caps/participation rates must be disclosed in the prospectus, and if there are changes to those rates, then the prospectus must be updated. This is consistent with the approach
in the RILA rulemaking, which only permits current upside rates to be posted online, with historical rates in an exhibit to the registration statement.

Response – Currently, many RILA issuers modify upside rates periodically based on market and other factors. The staff
currently permits RILA issuers to disclose current upside rates via a website incorporated by reference into the prospectus. Our RILA is designed to provide for dynamic rates (or buffer rates) based on market and other factors.

As discussed further below, we submit that the disclosure of current downside rates via a website incorporated by reference into the prospectus (i) is
consistent with the SEC’s layered disclosure approach and investor preferences expressed via recent SEC investor testing initiative; (ii) would avoid a confusing bifurcated disclosure approach for upside rates versus downside rates; and (iii)
is consistent with disclosure standards applied by the staff to other types of securities such as buffered ETFs.

 Importantly, we confirm the
prospectus will disclose the guaranteed minimum buffer rates for each Strategy Account Option. Accordingly, the website disclosure of current buffer rates would only disclose additional protection against loss. In other words, the website buffer
disclosure would not disclose additional risks, but rather would disclose additional protections beyond the minimum buffer rates disclosed in the prospectus. We believe that the disclosure of current buffer rates via a website would not require the
staff to allow additional factors to be varied by website disclosure.

 Improved Investor Experience. Allowing website disclosure of both
upside rates and downside rates would be consistent with the SEC’s layered disclosure approach and investor preferences as reflected in recent SEC investor testing initiatives. Requiring disclosure of RILA downside rates via prospectus
supplement would require RILA issuers to file and distribute frequent prospectus supplements to investors and distribution partners. Further, if the staff were to require such supplements to be filed via a post-effective amendment to the S-1
registration statement, this would effectively prohibit issuers from adjusting buffer rates based on current market conditions. This would constrain RILA issuers’ ability to update downside rates for investors in response to market conditions
and inhibit investors’ ability to access current rates on a more dynamic basis.

 Avoids Bifurcated Approach. Website disclosure will
allow investors to readily access both upside rates and downside rates by referring to a single source. Prohibiting website disclosure of downside rates would lead to a bifurcated approach where investors access upside rates online but receive a
prospectus supplement for downside rates. We submit that this would be cumbersome for investors and could potentially confuse investors. Similar to upside rates, we believe investors will find it more efficient to obtain current downside rates on
the company’s website identified in the prospectus than by receiving a potentially high number of prospectus supplements.

 We submit that to
the extent downside rates are simply the obverse of upside rates, they should be treated the same from a disclosure perspective. We recognize that the SEC’s July 1, 2024 release adopting rule and form amendments providing for the registration
of registered-index linked annuities (RILAs) (the “Adopting Release”) discusses posting upside rates on a website. However, this does not require the staff to conclude that website disclosure of downside rates are prohibited. We understand
that the SEC’s discussion of upside rates in the Adopting Release was a reflection of industry comments based on then-current RILA product design. As RILA product design evolve, the fundamental analysis in the Adopting Release is equally
applicable to upside rates and downside rates. As discussed below the SEC staff permits issuers on other forms to disclose current rates (including downside rates) on a website despite the fact that the relevant SEC form does not explicitly
reference such website disclosure.

 Precedent. The SEC staff currently permits a variety of issuers to disclose current downside rates on a
website specified in the prospectus. For example, many buffered exchanged traded funds (“ETFs”) registered on Form N-1A disclose current buffer rates on a website. The website disclosure of the current buffer is used by investors to make
purchase decisions after the start of the term (e.g., the one year hedge period). We submit that both downside rates and upside rates should be readily accessible on a website that is identified in the prospectus in a single access point.
Prohibiting website disclosure of downside rates would put RILA issuers at a competitive disadvantage relative to other products such as buffered ETFs.

We respectfully request the staff reconsider its position.

2.
 Comment – On the new Upside Parameter called “Lock.” We understand that the term
“Lock” is used to refer to a feature that “locks in” an index crediting rate if a specified threshold is met. To avoid potential investor confusion with the Performance Lock feature, which “locks in” Interim Value, we
think the company should change the terminology to refer to something other than just “Lock.” For example, referring to this feature throughout as a “Threshold Lock” would probably be sufficient to distinguish this from the
Performance Lock feature. Similarly, for consistency, we suggest changing the “Lock Buffer Rate” to something like “Threshold Lock Buffer Rate” and “Lock Threshold” to something like “Threshold Lock Rate.”

 Response – We appreciate the staff’s comment and share the staff’s goal of clear disclosure. In response to
the staff’s comment, we have revised the prospectus to clearly distinguish the Performance Lock feature from the Lock Upside Parameter. Specifically, Performance Lock is a feature that allows investors to lock in Interim Value under certain
Strategy Account Options; whereas Lock is an Upside Parameter that applies to different Strategy Account Options.

 As noted above, the Strategy
Account Options for which the Performance Lock feature is available are different from the Strategy Account Options that use Lock as an Upside Parameter. We have clearly identified the different Strategy Account Options to which each
feature applies.

 We believe the revisions clearly differentiate the two concepts.

Cover Page

3.
 Comment – After “minimum guaranteed rates” in the second sentence of the fifth paragraph,
insert “that may be established under the contract” and replace “available under the Contract” with “(other than Threshold Lock)”.

Response – Comment complied with.

4.
 Comment – In the fifth paragraph, please add a sentence that Lock Thresholds are guaranteed minimum
rates under the Contract.

 Response – Comment complied with.

5.
 Comment – Regarding the last sentence of the fifth paragraph, please clarify that the Lock Thresholds
are percentages.

 Response – Comment complied with.

6.
 Comment – Please replace “for all Strategy Account Options” in the fourth sentence of the
sixth paragraph with “that we will offer under any Strategy Account Options”.

 Response – Comment
complied with.

7.
 Comment – In the third sentence of the seventh paragraph, please replace “Lock Buffer Rates”
with “Buffer Rates” as all Buffer Rates can change over the life of the Contract if new Strategy Account Options are added. To suggest otherwise might confuse investors into thinking that the current Buffer Rates are the only ones that
will ever be available under the Contract.

 Response – Comment complied with.

8.
 Comment – In the first bullet point, please reconsider this disclosure with the response we received
to comment #15 in the response letter which states that the Interim Value will not apply to “free look” withdrawals which is based on a return of Purchase Payment minus Withdrawals. There are numerous references throughout the prospectus
to Interim Value applying to the “free look” provision”. Please ensure the disclosure is consistent.

Response – Interim Value will not apply to “free look” withdrawals that are based on a return of Purchase Payment. However,
if state law requires a refund of Contract Value rather than a refund of Purchase Payment, Interim Value will apply. We have reconciled the disclosure here and throughout the prospectus for consistency.

9.
 Comment – In the second bullet point, please add “free Withdrawal amounts, Performance Locks,
optional death benefit fees, death benefit payments, and annuitization” to Withdrawals and Surrenders that cause the Interim Value to be recalculated.

Response – We have revised the disclosure to add free Withdrawal amounts, optional benefit fees, death benefit payments, and
annuitization. Performance Lock does not cause the Interim Value to be recalculated. Performance Lock “locks” in the already calculated Interim Value of the Strategy Account Option. We have omitted Performance Lock from this sentence and
throughout the prospectus where appropriate.

10.
 Comment – In the second bullet point, please bold “100%”.

Response – Comment complied with.

11.
 Comment – In the second bullet point, please delete “however any such Withdrawal or Surrender
would be subject to the Minimum Withdrawal Value”. Unless the Company can sufficiently define “Minimum Withdrawal Value” all references to “Minimum Withdrawal Value” other than for the Fixed Account should be deleted
particularly when disclosing maximum loss potential of 100% from the Interim Value. This wording suggests to investors that the loss potential might not actually be 100%. If that is true, then the prospectus needs to be specific as to what the
Minimum Withdrawal Value is, how it is calculated, what the percentage is, and when it applies.

 Response – The
Minimum Withdrawal Value is the minimum amount required to be paid to a contract owner upon Surrender, payment of a death benefit of annuitization and is equal to the sum of the Fixed Account Option Minimum Withdrawal Value and the Strategy Account
Option Minimum Withdrawal Value(s). The definition of “Strategy Account Option Minimum Withdrawal Value” has been revised to state that the Strategy Account Option Minimum Withdrawal Value is equal to the contract owner’s Purchase
Payment amount allocated to the Strategy Account Option multiplied by 87.5% on the Contract Issue Date and thereafter moves in proportion to the Strategy Account Option Value which may be increased or decreased based upon Interim Value, Index
Credits or transfers, fees or withdrawals. We have revised the disclosure here and throughout the prospectus to state that a Surrender of the Contract

is subject to the Minimum Withdrawal Value.

12.
 Comment – In the second bullet point, please bold “100%” and delete “subject to the
Minimum Withdrawal Value”.

 Response – We have revised the bullet point to state: “The Interim Value
could be less than your investment in a Strategy Account Option even if the Index has had a positive performance since the Term Start Date. Withdrawals, Surrenders, free Withdrawal amounts (in states where a refund of Contract Value is required)
that cause the Interim Value to be recalculated could result in the loss of principal investment and previously applied Index Credit Rates, and such losses could be as high as 100%. However, your Surrender of the Contract would be subject to
the Minimum Withdrawal Value.”

13.
 Comment – Please add a sentence stating “Interim Value will not apply when calculating your
refund of the Purchase Payment” after the fourth sentence of the second paragraph after the bullets. Additionally, please include a reference to Appendix F: State Variations.

Response – Comment complied with.

 Special
Terms

14.
 Comment – In the definition of “Index Credit”, please revise “For Lock, the dollar
amount of gain or loss reflect in your Strategy Account Option Value on any day during the Term” to “For Threshold Lock, the dollar amount of gain reflected in your Strategy Account Option Value on the first day during the Term where the
Index Change meets or exceeds the Threshold Lock Rate, and if the Index Change does not meet or exceed the Threshold Lock Rate on or before the Term End Date, then the dollar amount of gain or loss reflected in your Strategy Account Option Value on
the Term End Date.”

 Response – Comment complied with.

15.
 Comment – Please delete “on a Strategy Account Option other than Lock” in the third sentence
of the definition of “Interim Value”.

 Response – Comment complied with.

16.
 Comment - Please revise the second sentence of the “Lock” definition as follows: “If you select a
Strategy Account Option with Threshold Lock and the positive Index Change meets or exceeds the Threshold Lock Rate on any day during the Term, you will receive an Index Credit Rate equal to the Lock Threshold Rate as of that date.”

 Response – Comment complied with.

17.
 Comment – Please revise the third and fourth sentence of the “Lock” definition as follows:
“When that occurs, you will no longer participate in Index performance, and you will not receive an additional Index Credit Rate on the Term End Date for that Strategy Account Option. After we apply the Index Credit Rate, you will be credited
with the Performance Lock Fixed Rate until the next Contract Anniversary.”

 Response – Comment complied
with.

18.
 Comment – Please clarify in the definition of “Lock Threshold” and throughout the prospectus
whether the Lock Threshold on any day must occur at Market Close or at any time throughout the trading day.

 Response
– We have clarified that the Lock Threshold must occur at Market Close in the definition of “Lock” and throughout the prospectus, where appropriate.

19.
 Comment – Please delete “For Lock, a feature that automatically
“locks-in” and credits an Index Credit Rate equal to the Lock Threshold if the Index Change meets or exceeds the Lock Threshold on any day

before the Term End Date.” from the definition of “Performance Lock”. In the sentence following, please delete “For all Strategy Account Options”. Please revise the
second to last sentence to state “You may exercise Performance Lock for one, some, or all of your applicable Strategy Account Options other than Strategy Account Options with Lock.” Please add a sentence that states “Performance Lock
is not available for a Strategy Account Option with Lock.”

 Response – Comment complied with.

20.
 Comment – In the definition of “Performance Lock Date”, pleas