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            Allianz Life Insurance Company of North America

            Erik Nelson

            Associate General Counsel, Senior Counsel

            Corporate Legal

            5701 Golden Hills Drive

            Minneapolis, MN  55416-1297

            Telephone:  763-765-7453

            Erik.Nelson@allianzlife.com

            www.allianzlife.com

  CORRESPONDENCE FILING

  April 13, 2023

  Mr. Mark Cowan, Senior Counsel

  Securities and Exchange Commission

  Division of Investment Management, Disclosure Review

  Office 100 F Street NE

  Washington, DC 20549-8626

        Re:

          Initial Filing on Form S-1, Submitted December 15, 2022, File No. 333-268820 (Index Advantage+SM Income)

  Mr. Cowan:

  We received additional comments from you on April 5, 2023, with respect to Registrants’
    above-referenced initial Registration Statement on Form S-1 (the “Initial Registration Statement”), submitted on December 15, 2022. This correspondence responds to your comments. We will make conforming changes to the prospectus in both the Form S-1
    and Form N-4 Registration Statements in the next pre-effective amendment to the above-referenced initial Registration Statement, as well as conforming changes, as applicable, to other products.

  April 5, 2023 PROSPECTUS COMMENTS

  ADDITIONS TO PRIOR COMMENTS

  General Comment:  See comments provided April 5, 2023, in connection with Post-Effective Amendment No. 1 to the Form S-1
    Registration Statement, Submitted December 16, 2022, File No. 333-264349 (Index Advantage® Income ADV Variable Annuity) (“IAI ADV Comments”).

  Response:  Conforming changes are made to
    the Initial Registration Statement in response to applicable IAI ADV Comments.

        1.

          Referring to Prior Comment #20 (prior prospectus comments, received February 14, 2023, are copied below with the prior responses, for your reference), consider clarifying the disclosure based on
            the response.

  Response:  Revised as requested to clarify
    that an Owner “can also transfer assets out of any locked Index Option, including 1-year Term Index Options, before the Term End Date by requesting an Early Reallocation.”

        2.

          Referring to Prior Comment #35 (below), we do not think the use of the term “Issue Date” is right in terms of the initial rates for Index Effective Dates within the guaranteed

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  period. It should be based on the date rates are reviewed with the application.

  Response:  Revised as requested to replace
    “Issue Date” with “date you signed your application.”

        3.

          Referring to Prior Comment #50 (below), clarify the disclosure in light of the prior response.

  Response:  Revised as requested to add
    “However, it is possible in periods of extremely low return that the Level Income Guarantee Payment Percentage could result in a higher initial Income Payment. In those circumstances we base Income Payments on total Purchase Payments adjusted for
    withdrawals instead of Contract Value.” to the second paragraph under HOW THE INCOME BENEFIT WORKS on page 79 of the prospectus.

        4.

          Referring to Prior Comment #52 (below), clarify whether withdrawals also include withdrawals to pay financial adviser fees.

  Response:  Revised as requested to clarify
    that Excess Withdrawals include “any financial adviser fees that you choose to have us pay from this Contract.”

        5.

          Referring to Prior Comment #57 (below), regarding the requirement to take a full Excess Withdrawal in the case that Contract Value is less than $2,000 prior to or following a partial Excess
            Withdrawal, we do not think the company should do this. It should, at a minimum, notify investors before this happens (i.e., that taking the withdrawal will act to
            terminate Income Payments and contact to terminate). Also, referring to the same disclosure in the third and fourth sentences under EXCESS WITHDRAWALS on page 85 of the prospectus, we believe this is problematic. Investors should at a minimum
            be advised of the consequences (i.e., end of Income Payment and Contract termination) of this withdrawal before processing.

  Response:  We note that minimum contract
    value requirements for taking withdrawals are a common feature of variable contracts and fully disclosed here. We are not aware of any requirements under the federal securities laws to provide a warning to a contract owner prior to processing a
    withdrawal request, including an Excess Withdrawal generally or an Excess Withdrawal that results in termination of a contract and its benefits specifically. Furthermore, we believe that a delay in processing a withdrawal request to provide such a
    warning could create problems under applicable contracts or regulations. Also, as a serious practical matter, the Company has not programmed system functionality to enable such a warning. The cost and time necessary to do so would be extraordinary.

  However, the fourth sentence referred to above is revised to read:  “A full Excess Withdrawal will cause Income Payments to stop and the Contract and all of its benefits to end. We will not provide a warning before you take an Excess Withdrawal, and there will be no opportunity to undo an Excess Withdrawal.” Additional
    disclosure also is added in the following sections, relating to the Income Benefit:  Overview, Risk Factors - Income Benefit Risks, Access to your Money, Benefits Available Under the Contract – Income Benefit, and Income Benefit - How the Income
    Benefit Works.

        6.

          Please conform cover pages for all RILA products to these comments to extent

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  applicable, including the Index Advantage Income ADV Post-Effective Amendment.

  Response:  Revised as requested.

        7.

          Referring to the bullet point list of Index Options on the cover page, given how much space this takes, consider a cross-reference to where these are listed.

  Response:  The Company submits that
    including the list of currently available Index Options on the cover is important to investor understanding of the product, as well as other disclosure on the cover (for example, the disclosure immediately following that “These Buffers, Floors, and
    minimum Trigger Rates, Caps, and Participation Rates for each Index Option, respectively, will not change for life of the Contract.”)

        8.

          Referring to the first full paragraph on page 2 of the prospectus, revise the sentence “However, with the Index Protection Strategy with Trigger and Index Protection Strategy with Cap the Daily
            Adjustment cannot be negative,” to clarify Contract fees and expenses could cause an Owner to lose principal and previously credited earnings.

  Response:  Revised as requested.

        9.

          Referring to the first full paragraph on page 2 of the prospectus, following the sentence “The Daily Adjustment could reflect significantly less gain, or more loss than we would apply to an
            Index Option at the end of a Term,” insert “Contract fees and expenses could cause your losses to be greater,” provided that the maximum does not take these into account.

  Response:  Revised as requested to add
    “Such losses will be greater if you take a withdrawal (including any financial adviser fees that you choose to have us pay from this Contract) that is subject to a withdrawal charge, or is a deduction of Contract fees and expenses.”

        10.

          Referring to the first full paragraph on page 2 of the prospectus, make the last sentence a new paragraph.

  Response:  Revised as requested.

        11.

          Referring to the third full paragraph on page 2 of the prospectus, begin a new paragraph at the fourth sentence (beginning “Withdrawals will reduce the Contract Value …”).

  Response:  Revised as requested.

        12.

          Referring to the fourth sentence of the third full paragraph on page 2 of the prospectus, add “and by more than the amount withdrawn” to the parenthetical so that it reads “(perhaps
            significantly and by more than the amount withdrawn),” if true.

  Response:  Revised as requested. The same
    edit also is made to each applicable instance of “(perhaps significantly),” including under What are the Contract’s Primary Features?, Withdrawal Charge Waivers and Deduction of Financial Adviser Fees, on page 21 of the prospectus in the Overview.

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        13.

          Specify the distributor on the cover.

  Response:  Revised as requested.

        14.

          Referring to the fourth bullet under RISKS ASSOCIATED WITH SUBSTITUTION OF AN INDEX AND LIMITATION ON FURTHER INVESTMENTS, on page 30 of the prospectus, delete this bullet point. We do not think
            other companies have all these and the first three bullets cover most circumstances when the index should be changed.

  Response:  We briefly note the following:

        •

          The Company’s right to substitute an Index when it determines “in its sole discretion” that such substitution is necessary is a contractual right reserved to the Company in the policy form,
            which was subject to the review and approval of the Company’s state insurance regulators.

        •

          The disclosure describes the circumstances under which Allianz Life may exercise that discretion. We note that the portion of the 4th bullet beginning “It is our policy that …” was originally
            added in response to a prior Staff comment given to the Company on June 17, 2021, on the Index Advantage Income ADV prospectus.

        •

          We are aware of competitors that have similar reserved rights. For example, Equitable Life Insurance Company (see, e.g., File No. 333-253036) and Brighthouse Life Insurance Company (see, e.g.,
            File No. 333-233240) reserve similar discretion for index substitutions (for example, “[w]e have the right to substitute an alternative index prior to Segment Maturity if . . . at our sole discretion we determine that our use of such Indices
            should be discontinued . . . .”).

        •

          Once issued, a Contract may be expected to continue for many decades. The Company must maintain flexibility to respond to future unanticipated events. The current disclosure describes the known
            types of events that might require a substitution, but the disclosure cannot foreclose the possibility of other events that cannot be foreseen.

  By follow-up communication on April 7, 2023, you requested that this bullet point be revised as follows:

  we determine in our sole discretion that the substitution is necessary.
        It is our policy that we will exercise this discretion only to respond as we deem necessary due  to unanticipated events outside of our direct control. This might
    include other events similar to those listed above, other changes to the Index (such as name or ownership changes) that legally may be considered a substitution or that do not align with our
        business strategy or values, or a breach by the Index provider of the Index intent or performance expectations.

  The bullet point is revised as requested.

        15.

          Referring to the second to last sentence on page 57 of the prospectus, under DAILY ADJUSTMENT, why is this different than maximum loss noted on cover?

  Response:  Revised to add the following
    information regarding maximum loss from the cover:  “The maximum potential loss from a negative Daily Adjustment is: 99% for the Index Precision

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  Strategy and Index Performance Strategy, and -35% for the Index Guard Strategy.”

        16.

          Referring to the last bullet prior to REQUESTING INCOME PAYMENTS on page 80 of the prospectus, make the bullet more prominent.

  Response:  Revised as requested to bold and
    italicize the text.

  PRIOR PROSPECTUS COMMENTS - Received February 14, 2023

  I. PROSPECTUS

        1.

          General Note:  We had a hard time following what was adjusted dollar for dollar and what was adjusted proportionately. Please consider including some sort of disclosure (e.g., a chart or bullet
            points) somewhere in the prospectus that clearly sets this out.

  Response:  We note that
    the various effects of additional Purchase Payments and withdrawals on the various values in the Contract are disclosed throughout the prospectus in the context of describing such values. Because the effects of various transactions on the different
    values are context-dependent, we submit that adding additional disclosure (e.g., a chart or bullet points) divorced from such context would not aid investor understanding and could cause confusion. We also submit that the existing disclosure regarding
    the effects of additional Purchase Payments and withdrawals on such values, throughout the prospectus, is adequate.

  COVER PAGE (Pages 1-2)

        2.

          In the Index Options bullet point on page 1 of the prospectus, please revise to specify the maximum loss with each type of downside protection, and, if space allows, consider using separate
            bullet points.

  Response:  Revised
    as requested.

        3.

          In the paragraph following the AZL Government Money Market bullet on page 1, please add the following language: “These Buffers, Floors, and minimum Trigger Rates, Caps, and Participation Rate
            for each Index Option, respectively, will not change for life of the Contract.”

  Response:  Revised as
    requested.

        4.

          In the last paragraph at the bottom of page 1, please specify the maximum loss resulting from application of Daily Adjustment. Please also add "Income Payments or" as follows:

  Before the end of an Index Option’s Term, if you take any type of withdrawal, execute the Performance Lock feature, begin
    Income Payments or Annuity Payments, or if we pay a death benefit or deduct a fee or expense, we base the transaction on the interim value of your Index Option investment, which
    includes the Daily Adjustment.

  Response:  Revised as
    requested

        5.

          In the last paragraph on page 1, please revise the following sentence as indicated:

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  If you select have multiple multi-year Term Index Options with different Term End Dates, there may be no time that any such transaction can be performed without the application of at least one Daily Adjustment.

  Response:  Revised as requested.

        6.

          In the second paragraph of page 2, please consider placing the following text in bold and revise as indicated:

  As such, withdrawals to pay financial adviser fees will be subject to withdrawal charges and, if withdrawn on a day other than a Term End Date, we apply the Daily Adjustment (which can be negative) to the Contract Value before deducting the withdrawal. Withdrawals will reduce the Contract Value, Cash
    Value, Guaranteed Death Benefit Value, and Income Payments (perhaps significantly), and may be subject to federal and state income taxes (including a 10% additional federal tax).

  Response:  Revised as requested.

        7.

          In the second paragraph on page 2, please consider moving the following sentence somewhere else where you discuss withdrawal charges generally as it seems a bit of place:  “A six-year withdrawal
            charge period applies to the intial and any additional Purchase Payment.”

  Response:  Revised as requested.

        8.

          Please also consider adding disclosure regarding the effect of proportionate adjustments made to Contract Value when withdrawals and other transactions occur.

  Response:  Contract Value is not adjusted
    proportionately but dollar-for-dollar for withdrawals or other transactions, as explained under Glossary – Contract Value, and elsewhere in the prospectus.