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            Allianz Life Insurance Company of New York

            John Hite

            Senior Counsel, Associate General Counsel

            Corporate Legal

            5701 Golden Hills Drive

            Minneapolis, MN  55416-1297

            Telephone: 763-765-7494

            John.Hite@allianzlife.com

            www.allianzlife.com

  CORRESPONDENCE FILING

  March 15, 2024

  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 Form S-1 Registration Statement, Submitted December 5, 2023, File No. 333-275895 (Allianz Index Advantage+ New York Variable
    Annuity)

  Mr. Cowan:

  We received comments from you on February 8, 2024, with respect to Registrant’s above referenced Initial Form S-1
    Registration Statement, filed on December 5, 2023. 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, and to other products.

  February 8, 2024 Prospectus Comments

  I. PROSPECTUS

  Cover Page

            1.

            The cover page discloses the maximum potential negative Performance Credit related to 10%, 20%, and 30% Buffers. Please confirm that the Index
              Options associated with those listed Buffers reflect the Index Options available on the Contract and that they will always be offered.

        Response:

          Allianz Life Insurance Company of New York (the “Company”) confirms that the listed Buffers on the cover page reflect those Index Options currently available. Additionally, the Company confirms
            that an Index Option cannot be removed from the Contract, unless it is simultaneously substituted by a new Index in accordance with the disclosures in the “Risks Associated with Substitution of an Index” section.

            2.

            Please add information relating to the minimum Participation Rates, Caps, and Trigger Rates available with Crediting Methods to the cover page.

        Response:

          In accordance with the Staff’s comment, the following sentences have been added to the cover page: “The Index Dual Precision Strategy and Index Precision Strategy provide a 5% minimum Trigger
            Rate. The Index Performance Strategy 1-year Term Index Options provide a 3% minimum Cap for the 30% Buffer, 4% minimum Cap for the 20% Buffer, and 5% minimum Cap for the 10% Buffer. The Index Performance

  Strategy 3-year Term Index Options provide a 9% minimum Cap for the 30% Buffer, 12% minimum Cap for the 20% Buffer, and
    15% minimum Cap for the 10% Buffer. Lastly, the Index Performance Strategy 6-year Term Index Options provide an 18% minimum Cap for the 30% Buffer, 24% minimum Cap for the 20% Buffer, and 30% minimum Cap for the 10% Buffer. Both the Index Performance
    Strategy 3-year and 6-year Term Index Options provide a 100% minimum Participation Rate.”

            3.

            Within the cover page, as well as various additional locations throughout the prospectus, terminology is applied inconsistently between Variable
              Option, underlying mutual fund, and variable subaccount. Please revise the associated language to consistently apply the terminology throughout the prospectus. Additionally, please ensure that disclosure is clear that investment in the
              Variable Option is an investment in the variable subaccount and not a direct investment in the fund.

        Response:

          The Company has revised the identified language consistent with the Staff’s comment. The Company will provide a revised prospectus under separate cover detailing the revisions made in accordance
            with the comment.

  Glossary

            4.

            Definition of Annuity Date: In the last sentence, there is reference to the maximum Annuity Date varying “depending on the requirements of the
              Financial Professional from which you purchased your Contract.” Please explain all distributor intermediary variations applicable to this statement.

        Response:

          The Company has removed the identified language from the sentence as the Company does not intend to provide any distributor intermediary variations applicable to the annuity date.

            5.

            Definition of Index Dual Precision Strategy: Please remove the reference to the Index Protection Strategy with Trigger as the Crediting Method is not
              available with this product.

        Response:

          The Company has removed the identified language consistent with the Staff’s comment.

            6.

            Definition of Index Dual Precision Strategy: This definition currently includes disclosure explaining market environments when the Crediting Method
              may perform best, as well as disclosure comparing the Crediting Method to other available options. Please consider whether this disclosure can either be removed or relocated within the prospectus.

        Response:

          The Company has removed the identified language consistent with the Staff’s comment. The definition of Index Dual Precision Strategy has been revised to state, “one of the Crediting Methods
            described in section 4, Valuing Your Contract. The Index Dual Precision Strategy calculates Performance Credits based on Index Returns subject to a Trigger Rate and 10% Buffer. This Crediting Method provides a positive Performance Credit for
            negative market movements when the loss is less than or equal to the 10% Buffer.  You can receive negative Performance Credits under this Crediting Method, which means you can lose principal and previous earnings. Significant losses beyond the
            10% Buffer for the Index Dual Precision Strategy can result in substantial loss of principal and previous earnings."

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            7.

            Definition of Index Performance Strategy: Similar to the preceding comment, please consider whether the disclosure included within this definition
              explaining the market environment when the Crediting Method may perform best, as well as disclosure comparing the Crediting Method to other available options, can be removed or relocated within the prospectus.

        Response:

          In accordance with the Staff’s comment, the Company has removed the sentence stating, “The Index Performance Strategy is more sensitive to large negative market movements because small negative
            market movements are absorbed by the 10%, 20%, or 30% Buffer.” Additional revisions have been made to the definition of the Index Precision Strategy to remove similar disclosure language.

  Key Information Table

            8.

            In the first footnote to the first table in the Ongoing Fees and Expenses section, please delete “net asset value” and replace it with “average net
              assets.”

  Response:  The Company respectfully declines to adopt the Staff’s comment.  The
    policy form similarly describes the charge as a percentage of the Variable Option’s net asset value and, for consistency purposes, the Company believes it is important to use the same terminology in the prospectus.  Also, the Form N-4 includes the
    following language in Item 2(c)(i)(C), which suggests there is flexibility in what calculations may be utilized in the table:

  “Explain, in a parenthetical or footnote to the table or each caption, the basis for each percentage (e.g., % of separate
    account value or benefit base, or % of net asset value).”

  Item 2(c)(i)(C) (Emphasis added).  Accordingly, the Company will continue to use the term “Variable Option’s net asset
    value” in that footnote.

            9.

            Within the section identifying restrictions on investments, please include clarifying language that “certain” Index Options may be made temporarily
              unavailable. In addition, consider reordering the sub-bullets to more clearly convey when Index Options can be made temporarily unavailable. Please also make the sub-bullet explaining that all Index Options can be made temporarily unavailable
              for Early Reallocation a bullet on its own following the sub-bullet list. Lastly, please confirm whether the bullet indicating that the Company reserves the right to discontinue accepting new allocations into specific Index Options is
              accurate.

        Response:

          The Company has revised and reordered the bullets and subbullets to: (1) indicate that certain Index Options may be made temporarily unavailable, (2) the particular groups of Index Options that
            may be made temporarily unavailable, and (3) that all Index Options may be made temporarily unavailable for Early Reallocation at any time, which means there may be times when Early Reallocation is unavailable to individuals. Lastly, we are
            removing the language reserving the right to discontinue accepting new allocations into specific Index Options as that is not allowed on this product.

            10.

            Please include a cross-reference within the section identifying restrictions on investments stating where additional information regarding the
              Company’s right to substitute a variable investment option can be found within the prospectus.

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        Response:

          Information regarding the Company’s right to substitute a variable investment option is found within the subsection “Substitution and Limitation on Holdings” of the prospectus section titled
            ‘Information Related to the Variable Option’s Underlying Fund’. The Company has revised the cross-reference to direct investors to this section of the prospectus for additional information.

  Overview of the Contract – What are the Phases of the Contract?

            11.

            Within the bullet describing the accumulation phase, there is a reference to additional Purchase Payments being subject to limitations. Please either
              specify those limitations or include a cross reference as to where an investor could find this information.

        Response:

          The Company has added the following sentence to the end of the identified paragraph: “For more information regarding additional Purchase Payment limitations, please see section 3, Purchasing the
            Contract – Purchase Requirements.”

            12.

            This section currently includes language explaining that the Company will provide notice when Index Options are made temporarily unavailable for a
              year or more. Please add additional language clarifying the notice that will be provided, and the timing of such notice, in the event Index Options are made temporarily unavailable.

        Response:

          The Company confirms that it will provide investors at least seven days’ notice prior to making Index Options temporarily unavailable. Accordingly, the identified language has been revised to
            state, “Subject to the following parameters, with at least seven days’ notice, we may make the Index Options temporarily unavailable if we are unable to support the minimum Trigger Rate or Cap due to yield on investments or the availability or
            cost of hedging.  This period of temporary unavailability could last a year or more.”

            13.

            Consider moving the sentence stating, “We can make all Index Options temporarily unavailable for Early Reallocation at any time” to a more
              appropriate or different section of the prospectus.

        Response:

          The Company has modified the paragraph to first list the various groups of Index Options that may be made temporarily unavailable, followed by the identified sentence in the Staff’s comment. The
            Company is of the opinion that the sentence should remain in this section as it provides valuable disclosure relating to the availability of Early Reallocation and its interplay with temporary unavailability of Index Options.

            14.

            In the list of currently available Crediting Methods, consider adding language indicating whether a particular Index is a total price Index. If any
              Indexes are total price Indexes, please include a reference in a parenthetical. Alternatively, prominently include language stating whether or not dividends are included in Index prices.

        Response:

          The Company has revised language beneath the Index Options subheader of this section to state, “The Index Options do not directly participate in the returns of the Indexes or the Indexes’
            component securities, and do not receive any dividends payable on these securities. Index returns would be higher if they included the dividends from the component securities. You should understand that you will have

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  no voting rights, no rights to receive cash dividends or other distributions, and no other rights with respect to the
    companies that comprise the Indexes.” The Company believes the added disclosure sufficiently informs investors that they are not directly invested in the Indexes nor do they receive any dividends payable.

  Fee Tables

            15.

            Consider revising the table of withdrawal charges to only include the first-year withdrawal charge amount with the remaining withdrawal charge
              amounts identified in a footnote to the table.

        Response:

          The Company respectfully declines to adopt the Staff’s comment. The Company is of the opinion that inclusion of the complete withdrawal charge table provides investors with valuable information
            regarding the impact of withdrawals throughout the period of time in which withdrawal charges would apply. Further, the Company believes this disclosure is consistent with the Form N-4 disclosure language stating the following.

  The Registrant may disclose the current charge, in addition to the maximum charge, if the disclosure of the current
    charge is no more prominent than, and does not obscure or impede understanding of, the disclosure of the maximum charge. In addition, the Registrant may include in a footnote to the table a tabular, narrative, or other presentation providing further
    detail regarding variations in the charge. For example, if deferred sales charges decline over time, the Registrant may include in a footnote a presentation regarding the scheduled reductions in the deferred sales charges.

  The Company believes its approach is not in conflict with the Form N-4 language in that the use of the word “may” in the
    Form N-4 indicates that the footnote approach is optional.  Moreover, the Company notes that such an approach is followed by other Registrants in their Form N-4 filings

  Risk Factors

            16.

            Within the section titled “Risks Associated with Changes to Trigger Rates, Caps, and Participation Rates, and Temporary Unavailability of Index
              Options”, please begin a new paragraph at the sentence that begins “You also risk the possibility that we may make Index Options temporarily unavailable...”.

        Response:

          The Company has revised the identified language consistent with the Staff’s comment.

            17.

            Within the section titled “Risks Associated with Changes to Trigger Rates, Caps, and Participation Rates, and Temporary Unavailability of Index
              Options”, please clarify the functionality of the temporary unavailability of Index Options contract feature. Specifically, consider adding clarifying language as to how temporary unavailability impacts amounts presently held within the AZL
              Government Money Market Fund subaccount (Variable Option) but for which allocation instructions were received that would othe