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    Principal Life Insurance Company

    711 High Street, Des Moines, IA 50392

    515 247 5111 tel

May 10, 2024

VIA EDGAR

Sonny Oh

Senior Counsel

U.S. Securities and Exchange Commission

Division of Investment Management – Disclosure Review and Accounting
Office

100 F Street NE

Washington, D.C. 20549

Re:          Principal
Life Insurance Co.

Registration Statement on Form S-1

File No. 333-275614

Principal Life Insurance Company
Separate Account B

Registration Statement on Form N-4

File Nos. 333-275615; 811-02091

Dear Mr. Oh:

Principal Life Insurance Co. (the “Company”), on behalf
of itself and Principal Life Insurance Company Separate Account B (the “Variable Account”), is transmitting for filing with
the Securities and Exchange Commission (the “Commission”) pre-effective amendments no. 2 to the above-referenced registration
statements (the “Registration Statements”), which are for certain single premium deferred index-linked and variable annuity
contracts titled Principal Strategic Income (the “Contract”). The filings are accompanied by acceleration requests pursuant
to Rule 461 under the Securities Act of 1933, requesting effectiveness of the Registration Statements, as amended, for no later than
May 13, 2024.

With this letter, the Company is also providing responses to comments
received from the staff of the Commission on May 8, 2024, regarding the Registration Statements. The Company previously filed on
February 21, 2024 and May 6, 2024 correspondence responding to staff comments received on the Registration Statements, and previously
filed pre-effective amendments no. 1 to the Registration Statements on May 6, 2024.

As part of this letter, the Company has included a marked version of
the prospectus reflecting changes made in response to the staff’s May 8, 2024 comments, as well as other changes made by the
Company. Such other changes made by the Company include (i) populating the rates for the Rate Sheet Supplement; (ii) correcting
the Lowest and Highest Annual Cost examples in the Key Information Table; (iii) changing the pagination convention for the prospectus’s
appendices to avoid confusion with the pagination of the Company financial statements; and (iv) correcting various cross-references
throughout.

Each of the staff’s comments is set forth below in bold, and
the Company’s response thereto immediately follows. Page references are to the marked copy of the prospectus that was provided
to the staff on May 6, 2024 to facilitate the staff’s review.

Prospectus

 1. On the cover page, in the third line of the third paragraph, please remove the disclosure stating that the prospectus describes
all intermediary-specific variations. The prospectus only describes state variations. See Comment 4 below.

Response: The prospectus has been revised accordingly.

 2. On p. 12 of the pdf, in the last sentence of the definition of “Surrender,” please add “Fee” after “the
GLWB.”

Response: The prospectus has been revised accordingly.

 3. On p. 27 of the pdf, in the two paragraphs above “Contract Features,” the staff notes that this disclosure was added
in response to Comment 53 of the prior comment letter. Please ensure that any changes made to similar disclosure later in the prospectus
are applied here and elsewhere, as applicable.

Response: The prospectus has been revised accordingly.

 4. On p. 28 of the pdf, in reference to Footnote 1 to the table, the prospectus should include intermediary-specific variations related
to the availability of Segment Options. Please supplementally confirm that the Company, with the first post-effective amendment, will
include an appendix to the prospectus that lists the Segment Options that are not available by broker-dealer, or otherwise disclose such
variations in the prospectus.

Response: The Company supplementally confirms that,
beginning with the first post-effective amendment, the Company will include an appendix to the prospectus that lists the Segment Options
that are not available by broker-dealer in accordance with the staff’s comment or any subsequent Commission or staff guidance that
otherwise applies to the Company.

 5. On p. 39 of the pdf, in the first paragraph under “Secure Income Protector (GLWB) Risk,” in the fourth sentence of
the first paragraph, please carve out death benefits from the reference to Surrender Charges.

Response: The prospectus has been revised accordingly.

 6. At the bottom of p. 40 of the pdf, the staff notes that this disclosure was added in response to Comment 53 of the prior comment
letter. Please ensure that any changes made to similar disclosure later in the prospectus are applied here and elsewhere, as applicable.

Response: The prospectus has been revised accordingly.

 7. On p. 98 of the pdf, in the sentence above the last paragraph, which states, “We will send you a written notice…,”
please delete “maximum” before “latest Annuitization Date.”

Response: The prospectus has been revised accordingly.

 8. In reference to the disclosure added in response to Comment 53 from the prior comment letter:

 a. On p. 112 of the pdf, in the paragraph at the end of the page, please add disclosure to the end of the paragraph stating that Owners
should not elect to fully Annuitize unless the annuity payments will be greater than the rider payments. Please also indicate that, by
fully Annuitizing, the Owner will be terminating the rider as well as any death benefit.

Response: The prospectus has been
revised accordingly.

 b. On p. 113 of the pdf, in reference to the second and last sentences of the second-to-last paragraph on the page, please also incorporate
this disclosure into the paragraph at the bottom of p. 112.

Response: The prospectus has
been revised accordingly.

 c. The option to receive fixed payments equal to the Secure Income Benefit Payment each Contract Year is not an annuity option, as
payments are not based on mortality rates. Please do not describe that election as an annuity option.

Response: The prospectus has
been revised accordingly.

 9. On p. 113 of the pdf, at the end of the fourth paragraph on the page, please delete “maximum” before “latest
Annuitization Date.”

Response: The prospectus has been revised accordingly.

 10. On p. 256 of the pdf (p. F-4 of Appendix F), in Example 11, please explain the bullet in the middle of the page which states,
 “Secure Income Benefit Payment = $4,000.”

Response: The prospectus has been revised accordingly.

Other Comments

 11. Please confirm that the financial statements, all outstanding exhibits (e.g., legal opinions and auditor consents), and
other items marked as to be added or updated by amendment will be included in the next pre-effective amendments to the Registration Statements.

Response: Confirmed.

 12. Please confirm that all exhibits and other documents incorporated by reference into (and exhibits to be filed with) the Registration
Statements will be hyperlinked.

Response: Confirmed.

 13. Please revise any incorporation by reference citation to include the appropriate SEC file number and type of registration form
or SEC filing, as applicable.

Response: The registration statements have been revised
accordingly.

* * *

The Company appreciates the staff’s attention to the Registration
Statements and this letter. If you have any questions or concerns about the responses set forth above, or the related revisions, please
contact the undersigned at 515-247-6785.

Sincerely,

  /s/ Scott Van Wyngarden

Scott Van Wyngarden

Counsel, Registrant

 FORM OF RATE SHEET SUPPLEMENT ¶ RATE SHEET SUPPLEMENT
DATED [ ]MAY 13, 2024 TO THE PROSPECTUS DATED [ ]MAY 13, 2024
FOR PRINCIPAL® STRATEGIC INCOME
We are issuing this Rate Sheet Supplement (this “Supplement”) to provide the Initial Secure Income
Percentages and Secure Income Deferral Credit percentage (the “Secure Income Percentages”) we will be
offering during the period set forth below. This Supplement replaces and supersedes any previous Rate Sheet
Supplement to the Principal® Strategic Income prospectus. When delivered in connection with the offer or
sale of a new Contract, the prospectus must be accompanied by this Supplement.
The Secure Income Percentages set forth below apply to applications signed between [ ]May 13, 2024
and [ ]June 26, 2024. The Secure Income Percentages may be different than those listed below for applications
signed after [ ]June 26, 2024. For that reason, it is important you have the Rate Sheet Supplement with
the most current Secure Income Percentages as of the date you sign the application.

 Secure Income Percentages for Level Income Option:
Single Life
Age of Covered Life on
the date the application is
signed
Initial Secure Income
Percentages Secure Income Deferral Credit
[ ] 45 [
]%
[
]% 4.00% 0.20%
[ ] 46 [
]%
[
]% 4.10% 0.20%
[ ] 47 [
]%
[
]% 4.20% 0.20%
[ ] 48 [
]%
[
]% 4.30% 0.20%
[ ] 49 [
]%
[
]% 4.40% 0.20%
[ ] 50 [
]%
[
]% 4.50% 0.20%
[ ] 51 [
]%
[
]% 4.60% 0.20%
52 4.70% 0.20%
53 4.80% 0.20%
54 4.90% 0.20%
55 5.00% 0.25%
56 5.10% 0.25%
57 5.20% 0.25%
58 5.30% 0.25%
59 5.40% 0.25%
60 5.50% 0.25%
61 5.60% 0.25%
62 5.70% 0.25%
63 5.80% 0.25%
64 5.90% 0.25%
65 6.00% 0.30%
66 6.10% 0.30%
67 6.20% 0.30%
68 6.30% 0.30%
69 6.40% 0.30%
70 6.50% 0.35%
71 6.60% 0.35%
72 6.70% 0.35%
73 6.80% 0.35%
74 6.90% 0.35%
75 7.00% 0.40%
76 7.00% 0.40%
77 7.00% 0.40%
78 7.00% 0.40%
79 7.00% 0.40%
80 7.00% 0.40%

 Joint Life
Age of Covered Life on
the date the application is
signed*
Initial Secure Income
Percentages Secure Income Deferral Credit
[ ] 45 [
]%
[
]% 3.50% 0.20%
[ ] 46 [
]%
[
]% 3.60% 0.20%
[ ] 47 [
]%
[
]% 3.70% 0.20%
[ ] 48 [
]%
[
]% 3.80% 0.20%
[ ] 49 [
]%
[
]% 3.90% 0.20%
[ ] 50 [
]%
[
]% 4.00% 0.20%
[ ] 51 [
]%
[
]% 4.10% 0.20%
52 4.20% 0.20%
53 4.30% 0.20%
54 4.40% 0.20%
55 4.50% 0.25%
56 4.60% 0.25%
57 4.70% 0.25%
58 4.80% 0.25%
59 4.90% 0.25%
60 5.00% 0.25%
61 5.10% 0.25%
62 5.20% 0.25%
63 5.30% 0.25%
64 5.40% 0.25%
65 5.50% 0.30%
66 5.60% 0.30%
67 5.70% 0.30%
68 5.80% 0.30%
69 5.90% 0.30%
70 6.00% 0.35%
71 6.10% 0.35%
72 6.20% 0.35%
73 6.30% 0.35%
74 6.40% 0.35%
75 6.50% 0.40%

 Joint Life
Age of Covered Life on
the date the application is
signed*
Initial Secure Income
Percentages Secure Income Deferral Credit
76 6.50% 0.40%
77 6.50% 0.40%
78 6.50% 0.40%
79 6.50% 0.40%
80 6.50% 0.40%
* Based on age of younger Covered Life on the date the application is signed.
Secure Income Percentages for Tiered Income Option:
Single Life
Initial Secure Income Percentages Secure Income Deferral Credit
Age of Covered
Life on the date
the application is
signed
While Contract
Accumulated
Value is greater
than $0
When Contract
Accumulated
Value is Reduced
to $0
While Contract
Accumulated
Value is greater
than $0
When Contract
Accumulated
Value is Reduced
to $0
[ ] 45 [
]%
[
]%
[
]%
[
]% 5.50% 2.50% 0.20% 0.15%
[ ] 46 [
]%
[
]%
[
]%
[
]% 5.60% 2.50% 0.20% 0.15%
[ ] 47 [
]%
[
]%
[
]%
[
]% 5.70% 2.50% 0.20% 0.15%
[ ] 48 [
]%
[
]%
[
]%
[
]% 5.80% 2.50% 0.20% 0.15%
[ ] 49 [
]%
[
]%
[
]%
[
]% 5.90% 2.50% 0.20% 0.15%
[ ] 50 [
]%
[
]%
[
]%
[
]% 6.00% 2.50% 0.20% 0.15%
[ ] 51 [
]%
[
]%
[
]%
[
]% 6.10% 2.50% 0.20% 0.15%
52 6.20% 2.50% 0.20% 0.15%
53 6.30% 2.50% 0.20% 0.15%
54 6.40% 2.50% 0.20% 0.15%
55 6.50% 2.50% 0.25% 0.20%
56 6.60% 2.60% 0.25% 0.20%
57 6.70% 2.70% 0.25% 0.20%
58 6.80% 2.80% 0.25% 0.20%
59 6.90% 2.90% 0.25% 0.20%
60 7.00% 3.00% 0.25% 0.20%
61 7.10% 3.10% 0.25% 0.20%
62 7.20% 3.20% 0.25% 0.20%

 Single Life
Initial Secure Income Percentages Secure Income Deferral Credit
Age of Covered
Life on the date
the application is
signed
While Contract
Accumulated
Value is greater
than $0
When Contract
Accumulated
Value is Reduced
to $0
While Contract
Accumulated
Value is greater
than $0
When Contract
Accumulated
Value is Reduced
to $0
63 7.30% 3.30% 0.25% 0.20%
64 7.40% 3.40% 0.25% 0.20%
65 7.50% 3.50% 0.30% 0.25%
66 7.60% 3.60% 0.30% 0.25%
67 7.70% 3.70% 0.30% 0.25%
68 7.80% 3.80% 0.30% 0.25%
69 7.90% 3.90% 0.30% 0.25%
70 8.00% 4.00% 0.35% 0.30%
71 8.00% 4.00% 0.35% 0.30%
72 8.00% 4.00% 0.35% 0.30%
73 8.00% 4.00% 0.35% 0.30%
74 8.00% 4.00% 0.35% 0.30%
75 8.00% 4.00% 0.40% 0.35%
76 8.00% 4.00% 0.40% 0.35%
77 8.00% 4.00% 0.40% 0.35%
78 8.00% 4.00% 0.40% 0.35%
79 8.00% 4.00% 0.40% 0.35%
80 8.00% 4.00% 0.40% 0.35%
Joint Life
Initial Secure Income Percentages Secure Income Deferral Credit
Age of Covered
Life on the date
the application is
signed*
While Contract
Accumulated
Value is greater
than $0
When Contract
Accumulated
Value is Reduced
to $0
While Contract
Accumulated
Value is greater
than $0
When Contract
Accumulated
Value is Reduced
to $0
[ ] 45 [
]%
[
]%
[
]%
[
]% 5.00% 2.50% 0.20% 0.15%
[ ] 46 [
]%
[
]%
[
]%
[
]% 5.10% 2.50% 0.20% 0.15%
[ ] 47 [
]%
[
]%
[
]%
[
]% 5.20% 2.50% 0.20% 0.15%
[ ] 48 [
]%
[
]%
[
]%
[
]% 5.30% 2.50% 0.20% 0.15%
[ ] 49 [
]%
[
]%
[
]%
[
]% 5.40% 2.50% 0.20% 0.15%
[ ] 50 [
]%
[
]%
[
]%
[
]% 5.50% 2.50% 0.20% 0.15%
[ ] 51 [
]%
[
]%
[
]%
[
]% 5.60% 2.50% 0.20% 0.15%

 Joint Life
Initial Secure Income Percentages Secure Income Deferral Credit
Age of Covered
Life on the date
the application is
signed*
While Contract
Accumulated
Value is greater
than $0
When Contract
Accumulated
Value is Reduced
to $0
While Contract
Accumulated
Value is greater
than $0
When Contract
Accumulated
Value is Reduced
to $0
52 5.70% 2.50% 0.20% 0.15%
53 5.80% 2.50% 0.20% 0.15%
54 5.90% 2.50% 0.20% 0.15%
55 6.00% 2.50% 0.25% 0.20%
56 6.10% 2.60% 0.25% 0.20%
57 6.20% 2.70% 0.25% 0.20%
58 6.30% 2.80% 0.25% 0.20%
59 6.40% 2.90% 0.25% 0.20%
60 6.50% 3.00% 0.25% 0.20%
61 6.60% 3.10% 0.25% 0.20%
62 6.70% 3.20% 0.25% 0.20%
63 6.80% 3.30% 0.25% 0.20%
64 6.90% 3.40% 0.25% 0.20%
65 7.00% 3.50% 0.30% 0.25%
66 7.10% 3.60% 0.30% 0.25%
67 7.20% 3.70% 0.30% 0.25%
68 7.30% 3.80% 0.30% 0.25%
69 7.40% 3.90% 0.30% 0.25%
70 7.50% 4.00% 0.35% 0.30%
71 7.50% 4.00% 0.35% 0.30%
72 7.50% 4.00% 0.35% 0.30%
73 7.50% 4.00% 0.35% 0.30%
74 7.50% 4.00% 0.35% 0.30%
75 7.50% 4.00% 0.40% 0.35%
76 7.50% 4.00% 0.40% 0.35%
77 7.50% 4.00% 0.40% 0.35%
78 7.50% 4.00% 0.40% 0.35%
79 7.50% 4.00% 0.40% 0.35%
80 7.50% 4.00% 0.40% 0.35%
* Based on age of younger Covered Life on the date the application is signed.
Determining Secure Income Percentages
The Secure Income Percentages for your Contract will be determined as described in this paragraph so
long as you satisfy the guidelines on submitting your application that are described in the prospectus. The
Secure Income Percentages in effect on the date you sign the application will apply to your Contract except
in the following situation:
If the Initial Secure Income Percentage or Secure Income Deferral Credit percentage in effect on the
date we receive your Premium Payment has increased from that in effect on the date you signed your
application, you will receive the Initial Secure Income Percentage, and Secure Income Deferral

 Credit percentage in effect on the date we receive your Premium Payment, provided that neither the
Initial Secure Income Percentage nor Secure Income Deferral Credit percentage has decreased during
that time.
The Secure Income Percentages applicable to your Contract will not change for the life of your
Contract.
For more information regarding the Initial Secure Income Percentages and Secure Income Deferral
Credit, see the prospectus.
This Supplement should be read and retained with the prospectus for Principal® Strategic Income. If
you would like another copy of the prospectus or a prior Rate Sheet Supplement, write us at Principal
Financial Group, P.O. Box 9382, Des Moines, Iowa 50306-9382 or call us at 1-800-852-4450 to request a
free copy. Rate Sheet Supplements are also available at www.principal.com/individuals/invest-retire/annuities,
as well as on the Securities and Exchange Commission’s EDGAR system at www.sec.gov (EDGAR
Contract ID No. C000248009). Certain terms used in this Supplement have special meanings. If a term is
not defined in this Supplement, it has the meaning given to it in the prospectus.
THIS SUPPLE