SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

      October 3, 2005

Mr. Jeffrey A. Ludrof
President and CEO
Erie Family Life Insurance Company
100 Erie Insurance Place
Erie, PA   16530

      Re:	Erie Family Life Insurance Company
		Amended Form 10-K for the fiscal year ended December 31,
2004
		Filed August 12, 2005
		File No. 002-39458

Dear Mr. Ludrof:

      We have reviewed your May 27, 2005, July 18, 2005 and August
8,
2005 responses to our May 6, 2005 comment letter.  We have also
reviewed the amended Form 10-K filed on August 12, 2005 and have
the
following comments.  In our comments, we have asked you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K/A for the fiscal year ended December 31, 2004

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 11

Critical Accounting Estimates, page 12

Deferred policy acquisition costs (DAC) asset, page 14

1. Refer to your response to comment two related to this section.
Please provide us your proposed disclosure to be included in
future
filings with a discussion of the sensitivity of your DAC to
changes
in gross profits or other factors.

Insurance liabilities, page 13

2. Refer to your response to comment two related to this section.
You state in your response related to the disclosures for your
insurance liabilities that a discussion of sensitivity is not
meaningful.  Please note that the comment only presents a
suggested
format that is intended to allow investors to better understand
the
sensitivity of your operations related to the factors that you
have
identified as key in establishing these reserves.  If you do not
feel
this proposed format is applicable to your business, then please
provide us similar disclosure in another format that will allow an
investor the desired insights into the sensitivity of these
liabilities to the key factors described.

Results of Operations, page 15

Revenues, page 15

3. Please tell us how your revised disclosures comply with the
items
requested in comment three and with your proposed disclosures
included in your letter to us dated July 18, 2005.  It appears the
effect of the decline in annuity deposits on the financial
condition
and operations of the business has not been discussed in the
amended
filing.  The discussion of the effect of the process review on new
premiums, described in your letter was similarly omitted.

Financial Statements, page 30

Note 4.  Investments, page 42

4. Refer to your response to comment eight.  Your response did not
address the fact that in spite of the way these transactions are
viewed, the affect of these transactions results in essence in a
borrowing which would be classified as a lending activity.  Please
explain to us why you feel that your intention in entering into
these
transactions is more persuasive than the substance of the
transaction
which is a borrowing.  Address specifically the guidance provided
in
SFAS 140 related to this type of transaction in your response.

*    *    *    *

      	Please respond to the comment within 10 business days or
tell us when you will provide us with a response.  Please furnish
a
letter that keys your response to our comment and provides
requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.

      You may contact Ibolya Ignat, Staff Accountant, at (202)
551-
3656, or Jim Atkinson, Accounting Branch Chief, at (202) 551-3674,
if
you have questions regarding the comments. In this regard, do not
hesitate to contact me, at (202) 942-1803.

							Sincerely,

							Jim B. Rosenberg
							Senior Assistant Chief
Accountant

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Jeffrey A. Ludrof
Erie Family Life Insurance Company
October 3, 2005
Page 3

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