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CORRESP
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CORRESP

 April 26, 2021

VIA EDGAR

 Commissioners

U.S. Securities and Exchange Commission

 100 F Street, NE

Washington, DC 20549

Re:
 Great American Life Insurance Company

Registration Statement on Form S-1

File No. 333-252915

Commissioners:

 We are transmitting for filing under the
Securities Act of 1933, as amended, a letter responding to comments with respect to the above-referenced Form S-1 Registration Statement (the “Response Letter”) for certain deferred annuity contracts
(the “Contracts”).

 The Response Letter addresses comments provided by the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) in a telephone call on April 21, 2021. For the Staff’s convenience, each comment is set forth in full below, followed by the Company’s response. Enclosed with the Response Letter are copies of
the pages changed as described in the responses below.

 GENERAL

1.
 Where a comment is made with regard to disclosure in one location of the Registration Statement, it is
applicable to all similar disclosure appearing elsewhere in the Registration Statement. Unless otherwise indicated, comments reference disclosure in the Index Frontier 7 Pro Annuity prospectus. Please make corresponding changes to the Index Frontier
5 Pro Annuity prospectus as applicable.

 RESPONSE: The Company confirms that applicable corresponding changes to
the Index Frontier 5 Pro Annuity prospectus were made.

 INDEX FRONTIER® 7 PRO ANNUITY PROSPECTUS

Examples - Impact of Withdrawals on Contract Values and Amounts Realized

2.
 In the sentence directly before the Examples – Impact of Withdrawals on Contract Values and Amounts
Realized section, please revise the section reference to match the name of the section.

 Commissioners

April 26, 2021

  Page
 2
 of 3

 RESPONSE: The Company made the requested revision.

3.
 In Examples B, C, D, and F in the Examples - Impact of Withdrawals on Contract Values and Amounts Realized
section, please explain in the narrative following the table why the “Amounts Withdrawn” are different between the two strategies.

RESPONSE: The Company added the following explanation to the beginning of the narrative following the table in Example B:

“*Note: The withdrawal is taken proportionally from each Indexed Strategy, based on the ratio of that Strategy’s value to the total
value of all Indexed Strategies immediately before the withdrawal. In this example, the total value of all Indexed Strategies immediately before the withdrawal was $90,634 ($44,819 + $45,815). The S&P 500 Growth Strategy value was 49.45% of that
total value ($44,819 / $90,634 = 49.45%), so 49.45% of the $10,000 withdrawal ($4,945) was taken from it. The S&P 500 Buffer Strategy value was 50.55% of that total value ($45,815 / $90,634 = 50.55%), so 50.55% of the $10,000 withdrawal ($5,055)
was taken from it.”

 The Company added similar explanations to the beginning of the narrative following the tables in Examples C, D,
and F.

4.
 In the last paragraph of the discussion section after Example B in the Examples - Impact of Withdrawals on
Contract Values and Amounts Realized section, please change the phrase “more of the withdrawal being taken from the Buffer Strategy” to “more of the withdrawal being taken from the Buffer Strategy’s value” Please also
make similar changes in the discussion sections after Examples C, D, and F.

 RESPONSE: The Company made the
requested revisions.

5.
 In the table in Example C in the Examples - Impact of Withdrawals on Contract Values and Amounts Realized
section, please revise the amount of Daily Charges through Day 146 for the S&P 500 Buffer Strategy to “$201”.

RESPONSE: The Company made the requested revision.

INDEX FRONTIER® 5 PRO ANNUITY PROSPECTUS

Examples - Impact of Withdrawals on Contract Values and Amounts Realized

6.
 In the table in Example A in the Examples - Impact of Withdrawals on Contract Values and Amounts Realized
section, please change the amount of Daily Charges through Day 146 for each Indexed Strategy from “$100” to “$201”, and revise any subsequent calculations affected by this change.

 Commissioners

April 26, 2021

  Page
 3
 of 3

 RESPONSE: The Company notes that the Daily Charge amount in the table in Example A can
be calculated using the following formula: Investment Base on the Term Start Date (or on most recent withdrawal date) – (Investment Base on the Term Start Date (or most recent withdrawal date) x (1 – Daily Fee Rate) ^ number of days
elapsed since Term Start Date (or most recent withdrawal).

 On Day 146 in Example A, that formula produces the following result: $50,000 -
($50,000 x (1 - 0.0000137329) ^ 146) = $100.

 As a result, the Company respectfully declined to make the requested revision.

The Company believes that the Response Letter addresses in full the Staff comments.

If you have any questions regarding the Company responses, please contact the undersigned at 513.412.1401 or at jdomaschko@gaig.com.

Sincerely,

/s/ John V. Domaschko

John V. Domaschko

Divisional Assistant Vice President

Great American Life Insurance Company

cc:
 John V. Domaschko, Great American Life Insurance Company

John P. Gruber, Great American Life Insurance Company

Dodie Kent, Eversheds Sutherland (US) LLP

-14%

-10
%

-12
%

-10
%

-10
%

-10
%

-8
%

-10
%

-6
%

-10
%

-4
%

-16%

-10
%

-14
%

-10
%

-12
%

-10
%

-10
%

-10
%

-8
%

-10
%

-6
%

-18%

-10
%

-16
%

-10
%

-14
%

-10
%

-12
%

-10
%

-10
%

-10
%

-8
%

-20%

-10
%

-18
%

-10
%

-16
%

-10
%

-14
%

-10
%

-12
%

-10
%

-10
%

-22%

-10
%

-20
%

-10
%

-18
%

-10
%

-16
%

-10
%

-14
%

-10
%

-12
%

 In general, Growth Strategies are designed to protect against larger negative Index Changes, while Buffer Strategies are
designed to protect against smaller negative Index Changes. When identical investments are made in a Growth Strategy and a Buffer Strategy using the same Index over the same Term, a negative change in the Index produces the following results:

•

 a negative Index Change between 0% and -10%, measured on any day, would
have a greater negative impact on the Growth Strategy

•

 a negative Index Change between -10% and
-20% could have a greater negative impact on either strategy, depending on the Index Change and the size of the Buffer on the day the Index Change is measured

•

 a negative Index Change below -20%, measured on any day, would have a
greater negative impact on the Buffer Strategy

 See Examples - Impact of Withdrawals on Contract Values and Amounts Realized
Indexed Strategy Values section below for examples that illustrate these concepts.

 Examples - Impact of
Withdrawals on Contract Values and Amounts Realized

 These examples are intended to show you how a withdrawal from an Indexed Strategy before the end
of the Term affects the Indexed Strategy values, Vested Gains and Losses, and amounts realized at the end of the Term. These examples assume that you allocate a $50,000 Purchase Payment to the S&P 500
Growth/-10% Floor Strategy and a $50,000 Purchase Payment to the S&P 500 10% Buffer Strategy. The examples assume that the withdrawals are covered by the Free Withdrawal Allowance and therefore no Early
Withdrawal Charges apply. If Early Withdrawal Charges did apply, the amounts realized at the end of the Term would be reduced by both the withdrawal and the amount of the Early Withdrawal Charge.

Example A: Withdrawal When Index Rising Steadily

 Impact of $10,000 Withdrawal on Day 146 of Term

 S&P 500 Growth Strategy

 S&P 500 Buffer Strategy

 Investment Base at Term Start

 $50,000

 $50,000

 Index Value at Term Start

 1000

 1000

 Daily Charges through Day 146

 $201

 $201

 Remaining Investment Base on Day 146

 $50,000 - $201 = $49,799

 $50,000 - $201 = $49,799

 Index Value at Date of Withdrawal

 1040

 1040

 Positive Index Change

 (1040 – 1000) / 1000 = 4%

 (1040 – 1000) / 1000 = 4%

 Maximum Gain

 Gain of 12%

 Gain of 14%

 Positive Index Change Limited by Maximum Gain

 4%

 4%

 Vesting Factor on Day 146

 25%

 25%

 Vested Gain as a Percentage

 4% x 25% = 1% Vested Gain

 4% x 25% = 1% Vested Gain

 Vested Gain in Dollars

 $49,799 x 1% = $498 Vested Gain

 $49,799 x 1% = $498 Vested Gain

 Strategy Value before Withdrawal

 $49,799 + $498 = $50,297

 $49,799 + $498 = $50,297

 Amount Withdrawn

 $5,000

 $5,000

 Percentage Reduction in Strategy Value

 $5,000 / $50,297 = 9.94%

 $5,000 / $50,297 = 9.94%

 Proportional Reduction in Investment Base

 $49,799 x 0.0994 = $4,950

 $49,799 x 0.0994 = $4,950

 Remaining Investment Base after Withdrawal

 $49,799 - $4,950 = $44,849

 $49,799 - $4,950 = $44,849

 Value at End of Term

 S&P 500 Growth Strategy

 S&P 500 Buffer Strategy

 Remaining Investment Base after Withdrawal

$44,849

$44,849

 Daily Charges from Day 147 to Term End

$270

$270

 Remaining Investment Base at Term End

$44,849 - $270 = $44,579

$44,849 - $270 = $44,579

 1

 Buffer on Day 146 of Term

N/A

 10% x (365-219)/365 = 4% Buffer

 Negative Index Change Absorbed by Buffer

N/A

 -4%

 Negative Index Change after Buffer

N/A

 -12% — 4% = -8%

 Vested Loss as a Percentage

 -10% x 100% = 10% Vested Loss

 -8% x 100% = 8% Vested Loss

 Vested Loss in Dollars

 $49,799 x 10% = $4,980 Vested Loss

 $49,799 x 8% = $3,984 Vested Loss

 Strategy Value before Withdrawal

 $49,799 - $4,980 = $44,819

 $49,799 - $3,984 = $45,815

Amount Withdrawn*

 $4,945

 $5,055

 Percentage Reduction in Strategy Value

 $4,945 / $44,819 = 11.03%

 $5,055 / $45,815 = 11.03%

 Proportional Reduction in Investment Base

 $49,799 x 0.1103 = $5,493

 $49,799 x 0.1103 = $5,493

 Remaining Investment Base after Withdrawal

 $49,799 - $5,493 = $44,306

 $49,799 - $5,493 = $44,306

 Value at End of Term

 S&P 500 Growth Strategy

 S&P 500 Buffer Strategy

 Remaining Investment Base after Withdrawal

$44,306

$44,306

 Daily Charges from Day 147 to Term End

$267

$267

 Remaining Investment Base at Term End

$44,306 - $267 = $44,039

$44,306 - $267 = $44,039

 Index Value at Term Start

1000

1000

 Index Value at Term End

1130

1130

 Positive Index Change

(1130 - 1000) / 1000 = 13%

(1130 - 1000) / 1000 = 13%

 Maximum Gain

Gain of 12%

Gain of 14%

 Positive Index Change Limited by Maximum Gain

12%

13%

 Vesting Factor at Term End

100%

100%

 Vested Gain as a Percentage

12% x 100% = 12% Vested Gain

13% x 100% = 13% Vested Gain

 Vested Gain in Dollars

$44,039 x 12% = $5,285 Vested Gain

$44,039 x 13% = $5,725 Vested Gain

 Strategy Value at Term End

$44,039 + $5,285 = $49,324

$44,039 + $5,725 = $49,764

*Note:
 The withdrawal is taken proportionally from each Indexed Strategy, based on the ratio of that
Strategy’s value to the total value of all Indexed Strategies immediately before the withdrawal. In this example, the total value of all Indexed Strategies immediately before the withdrawal was $90,634 ($44,819 + $45,815). The
S&P 500 Growth Strategy value was 49.45% of that total value ($44,819 / $90,634 = 49.45%), so 49.45% of the $10,000 withdrawal ($4,945) was taken from it. The S&P 500 Buffer Strategy value was 50.55% of that total value ($45,815 / $90,634 =
50.55%), so 50.55% of the $10,000 withdrawal ($5,055) was taken from it.

 S&P 500 Growth Strategy

In this example, the amount you realized on your $50,000 investment in the S&P 500 Growth Strategy at the end of the Term is $54,269 ($4,945 withdrawal
plus the $49,324 Strategy value at the end of the Term).

 Had no withdrawal occurred, your S&P 500 Growth Strategy value at the end of the Term would
have been $55,440 ($50,000 original Investment Base minus total Daily Charges of $500 and plus $5,940 gain ($49,500 x 12%)).

 This hypothetical Strategy
value of $55,440 exceeds the amount realized of $54,269 because:

•

 the loss at the time of the withdrawal caused the reduction in the Investment Base to be greater than the actual
amount withdrawn ($4,945 - $5,493 = -$548); and

•

 the subsequent gain at the term end was calculated on a smaller Investment Base, which caused that gain to be
smaller than the hypothetical gain ($5,285 - $5,940 = -$655); and

•

 the Daily Charges from Day 147 to Term End are lower than they would have been without the withdrawal by $32
because they are being applied to a decreased Investment Base.

 The result for the S&P 500 Growth Strategy (-$548 + -$655 + $32 =
-$1,171) is equal to the difference between the hypothetical Strategy value and the amount realized ($55,440 - $1,171 = $54,269).

 2

 S&P 500 Buffer Strategy

The amount you realized on your $50,000 investment in the S&P 500 Buffer Strategy at the end of the Term is $54,819 ($5,055 withdrawal plus the $49,764
Strategy value at the end of the Term). Had no withdrawal occurred, your S&P 500 Buffer Strategy value at the end of the Term would have been $55,935 ($50,000 original Investment Base minus total Daily Charges of $500 and plus $6,435 gain
($49,500 x 13%)). This hypothetical Strategy value exceeds the amount realized for the same reasons described above for the S&P 500 Growth Strategy.

Your investment in the S&P 500 Buffer Strategy outperformed the S&P 500 Growth Strategy by $550 in this example. The amount you realized under the
Buffer Strategy ($54,819) exceeds the amount you realized under the Growth Strategy ($54,269) for two reasons: (1) at the time of the withdrawal, the Buffer absorbed more of the negative Index Change (4 percentage points of the -12% change) than the Maximum Loss absorbed (2 percentage points of the -12% change), thus resulting in more of the withdrawal being taken from the Buffer
Strategy’s value even though the Investment Base of both strategies was reduced by the same amount, and (2) the Index Change at the end of the Term exceeded the Growth Strategy’s lower Maximum Gain, thus increasing the
Buffer Strategy’s value by more than the increase in the Growth Strategy’s value.

 Example C: Withdrawal When Index Falling Steadily

 Impact of $10,000 Withdrawal on Day 146 of Term

 S&P 500 Growth Strategy

 S&P 500 Buffer Strategy

 Investment Base at Term Start

$50,000

$50,000

 Daily Charges through Day 146

$201

$100201

 Remaining Investment Base on Day 146

$50,000 - $201 = $49,799

$50,000 - $201 = $49,799

 Index Value at Term Start

1000

1000

 Index Value at Date of Withdrawal

980

980

 Negative Index Change

(980 - 1000) / 1000 = -2%

(980 - 1000) / 1000 = -2%

 Maximum Loss

Loss of 10%

N/A

 Negative Index Change Limited by Maximum Loss

-2%

N/A

 Buffer on Day 146 of Term

N/A

10% x (365-219)/365 = 4% Buffer

 Negative Index Change Absorbed by Buffer

N/A

Entire -2% Index Change

 Negative Index Change after Buffer

N/A

0%

 Vested Loss as a Percentage

-2% x 100% = 2% Vested Loss

0% Vested Loss

 Vested Loss in Dollars

$49,799 x 2% = $996 Vested Loss

$0 Vested Loss

 Strategy Value before Withdrawal

$49,799 - $996 = $48,803

$49,799 - $0 = $49,799

 Amount Withdrawn*

$4,949

$5,051

 Percentage Reduction in Strategy Value

$4,949 / $48,803 = 10.14%

$5,051 / $49,799 = 10.14%

 Proportional Reduction in Investment Base

$49,799 x 0.1014 = $5,050

$49,799 x .0.1014 = $5,050

 Remaining Investment Base after Withdrawal

$49,799 - $5,050 = $44,749

$49,799 - $5,050 = $44,749

 Value at End of Term

 S&P 500 Growth Strategy

 S&P 500 Buffer Strategy

 Remaining Investment Base after Withdrawal

$44,749

$44,749

 Daily Charges from Day 147 to Term End

$269

$269

 Remaining Investment Base at Term End

$44,749 - $269 = $44,480

$44,749 - $269 = $44,480

 Index Value at Term Start

1000

1000

 Index Value at Term End

860

860

 Negative Index Change

(860 - 1000) / 1000 = -14%

(860 - 1000) / 1000 = -14%

 Maximum Loss

Loss of 10%

N/A

 Negative Index Change Limited by Maximum Loss

-10%

N/A

 Buffer at End of Term

N/A

10% Buffer

 Negative Index Change Absorbed by Buffer

N/A

-10%

 Negative Index Change after Buffer

N/A

-14% — 10% = -4%

 Vested Loss as a Perc