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CORRESP
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CORRESP

  June 21, 2022

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. 333-263740

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 the Index Achiever Advisory
Annuity and the Index Achiever Annuity contract (the “Contracts”). The Company is filing a pre-effective amendment filed pursuant to Rule 472 under the Securities Act, as requested.

The Response Letter addresses comments provided by the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) in
a letter dated May 20, 2022. For the Staff’s convenience, each comment is set forth in full below, followed by the Company’s response.

 In
a later filing, the Company intends to include a separate prospectus for each of the two Contracts. The two prospectuses will be essentially identical, except the Index Achiever prospectus will include fewer indexed strategies than the Index
Achiever Advisory prospectus. As a result, the Registration Statement includes only a prospectus for the Index Achiever Advisory contract and a Part II for your review.

The Company will respond to any further comments expeditiously. If the Company can be of any help in facilitating your review of these comments, please do not
hesitate to contact me.

 GENERAL

1.
 Please confirm that figures and date references will be updated as necessary and all missing information,
including all information about Great American Life and all exhibits and financial statements, will be filed in pre-effective amendments to the Registration Statement. We may have additional comments on such
portions when you complete them in the pre-effective amendments, on disclosures made in response to this letter, on information supplied supplementally, or on exhibits filed in the pre-effective amendments.

  Commissioners

June 21, 2022

 Page 2 of 12

 RESPONSE: The Company so confirms.

2.
 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. Comments reference disclosure in the courtesy copy of the Index Achiever Advisory Annuity Registration Statement provided to staff—please make corresponding
changes to the prospectus for the Index Achiever Annuity, as applicable.

 RESPONSE: The Company has made conforming changes as
requested.

3.
 Please clarify supplementally whether there are any guarantees or support agreements with third parties to
support any Contract features or benefits, or whether the Company will be solely responsible for any benefits or features associated with the Contracts.

RESPONSE: The Company confirms that the Company will be solely responsible for any benefits or features associated with the Contracts. From time to time, the
Company may choose to reinsure some of the Company’s obligations under the Contract through a reinsurance agreement, while retaining primary liability for all benefits under the Contract.

4.
 Please note that because the registration statement will go effective 135 days after the end of the
Company’s last fiscal year end, interim financial statements as required by Rule 3-12 of Regulation S-X will need to be included.

RESPONSE: The Company intends to include interim financial statements as of March 31, 2022 in the registration statement.

Prospectus Cover

5.
 The Company states that “Indexed Strategies provide returns based, in part, on the rise or fall of an
Index, which may be a market index, such as the S&P 500 Index, or the share price of an exchange-traded fund, such as an iShares ETF or a SPDR ETF. The returns of an Index do not include reinvestment of any dividends.” To make clearer that
the Indexed Strategies reflect only price returns on an Index, please (i) insert “price” immediately before “returns based” and (ii) replace “include reinvestment of any dividends” with “reflect the
payment of dividends by the Index.” Please make corresponding changes throughout the prospectus, as necessary.

 RESPONSE: The
Company has revised the paragraph to state: “Indexed Strategies provide price returns based, in part, on the rise or fall of an Index, which may be a market index, such as the S&P 500 Index, or the share price of an exchange-traded fund,
such as an iShares ETF or a SPDR ETF. The returns of an Index do not reflect the payment of dividends by stocks that make up the S&P 500 or by the ETF that is used as an Index.”

  Commissioners

June 21, 2022

 Page 3 of 12

6.
 In the first paragraph of page 2, given the long term nature of the Contract, please identify at least one
Indexed Strategy currently offered that will always be offered. Please revise other disclosure in the prospectus consistent with this change, including the last sentence of “Loss of Principal Related to Indexed Strategies” disclosure in
the “Risk Factors” section. Also, in the statement “[i]n addition, any reduction in the available number of Index Strategies to just one Indexed Strategy may reduce your opportunity to increase your Account Value,” please delete
“to just one Indexed Strategy.” Any reduction in the available number of Index Strategies may reduce an investor’s opportunity to increase Account Value.

RESPONSE: The Company has identified the S&P 500 1-Year -10% Floor with
Cap Indexed Strategy as a strategy that will always be offered, and has made the requested revisions.

7.
 In the bullet point regarding the floor, please revise the sentence “If the Index falls by more than 10%,
the decrease for the Term will be 10%” to show that the decrease is negative (-10%).

RESPONSE: The Company added the following phrase to the end of that bullet point: “meaning that there will be a 10% reduction in the Strategy
value.” The Company prefers to avoid inserting a negative sign, since a “decrease of -10%” can be misinterpreted as an increase of 10%.

8.
 In the bullet point regarding the Buffer, and elsewhere in the prospectus as necessary, to make clearer that
the Buffer does not serve as a floor for losses, please revise “is a portion of any fall in the Index over the Term that is disregarded” as “provides a buffer against the first 10% of any fall in the Index over the Term.” Please
also add a numerical example of how the Buffer works (e.g., if the Index falls by 50%, the Buffer limits losses on the Strategy value to 40%).

RESPONSE: The Company has made the requested revisions and added a numerical example.

9.
 The Company states that “[t]he S&P 500 6-year 10% Buffer with
Participation Rate Indexed Strategy will only be available for Terms that begin in the first Contract Year.” Please add that the Strategy may not be renewed.

RESPONSE: The Company has made the requested revisions.

10.
 On p. 3, the fifth paragraph directs readers to additional information regarding risk factors on pages 13-18 and pages 79-83. Please update these page references as the first set of references is inaccurate and the second set does not exist. Also, all risk factors should be
together in the prospectus. Accordingly, please move the risks associated with the Indexes located later in the prospectus to the “Risk Factors” section.

RESPONSE: The Company has updated the first set of references to the risk disclosures, but notes that these references may change again in subsequent filings.
The Company has bracketed the second set of disclosures, which refer to risk disclosures that routinely appear in Section II of the Company’s registration statements.

  Commissioners

June 21, 2022

 Page 4 of 12

11.
 Please revise references to “systematic withdrawals” to “automatic withdrawals.”

 RESPONSE: The Company has revised such references to “automated withdrawals”.

12.
 On p. 4, the third paragraph states that the Contract “is intended to be used by investors who have
engaged these investment advisors and investment advisor representatives to manage their Contract for a fee.” Please also state that if an investor elects to pay the advisory fee from his or her account value, then this deduction, like all
other withdrawals, will reduce the death benefit and account value and that this reduction could be significant and more than the dollar amount of the deduction. Further, please disclose that such advisory fee deductions from account value may be
subject to federal and state income taxes and a 10% federal penalty tax if federal or state authorities determine that these deductions are taxable.

RESPONSE: The Company has made the first requested revision. In response to the second requested revision, the Company has instead added a cross-reference to
the “Withdrawals to Pay Advisory Fees” section, which provides more details regarding the likelihood that authorities will determine that these deductions are taxable.

13.
 The cover page is four pages long. Please move the list of Index Strategies to the Summary, the Index
disclaimers on page three to another location in the prospectus, and otherwise streamline the cover page disclosure to shorten its length to one page. See 501(b) of Regulation S-K.

RESPONSE: The Company has moved the Index disclaimers to the “Indexed Strategies” subsection of the “Summary” section. The Company notes
that the remaining disclosures on the cover page follow the same format as the Company’s other registration statements on Form S-1, which have been lengthened in the past at the Staff’s request. The
Company respectfully requests that the rest of the cover page remain intact.

14.
 Please make the entire paragraph that begins with “[i]f you purchase a Contract, you may cancel it within
20 days after you receive it” more prominent.

 RESPONSE: The Company has made the requested revision.

Special Terms

15.
 We note that in the definitions of Floor, Buffer and Downside Participation Rate, the Company states that
“In the future, we may offer a new Strategy with a [Floor/ Buffer/ Downside Participation Rate] that is more or less than’’ the rate currently offered. Given the Company’s right to eliminate all of the currently offered Indexed
Strategies, please revise this disclosure to specify the minimum Floor, Buffer, and Downside Protection Rate that will apply to all new Index Strategies. Similarly, the minimum Cap and Upside Participate Rate for new Index Strategies should also be
specified.

  Commissioners

June 21, 2022

 Page 5 of 12

 RESPONSE: The Company has not made any changes in response to this Comment 15, because the Company made
changes in response to Comment 6 that removed the right to eliminate all of the currently offered Indexed Strategies.

 Summary

16.
 Please replace the list of Indexed Strategies here with the one shown on the cover, which reflects the Index,
Term, Positive Return Factor, and Negative Return Factor.

 RESPONSE: The Company has made the requested revision.

17.
 Please include a separate paragraph summarizing the key points relating to the deduction of third-party
advisory fees from Account Value. Please include a cross-reference to the section titled “Cash Benefit – Withdrawals to Pay Advisory Fees” and to the discussion on page 52.

RESPONSE: The Company has made the requested revision.

18.
 Please state in this section that all amounts owed under the Contract are solely the obligation of the Company
and that those obligations are subject to the Company’s creditworthiness and claims paying ability.

 RESPONSE: The Company has
added the following paragraph to the end of the “Indexed Strategies” subsection of the “Summary” section:

 “The
Contract doesn’t invest in any equity, debt, or other investments. If you buy this Contract, you aren’t investing directly in an Index, in the stocks included in S&P 500 Index, in the securities or other assets held by an iShares ETF,
in any underlying index tracked by an iShares ETF, or in the securities or other assets held by such underlying index. All benefits and guarantees under the Contract are the obligations of Great American Life and are subject to the credit
worthiness and claims-paying ability of Great American Life.”

 Indexed Strategy Value Before End of Term

19.
 Please revise this section to provide a plain English description of how the Index Strategy Value is determined
before the end of the Term, including to make the point that the Daily Value Percentage is designed to reflect daily changes in the then current estimate of the expected value at the end of the Term of the Index along with the examples listed in the
first paragraph. Please relocate the more detailed discussion and formulas to the section titled “Indexed Strategy Value Before End of Term” that begins on p. 28.

RESPONSE: The Company has made the requested revisions. The “Special Terms Related to Daily Value Percentage” and “Indexed Strategy Value
Before End of Term” sections made similar disclosures, so the disclosures removed from the “Summary” section have not been added anywhere else.

  Commissioners

June 21, 2022

 Page 6 of 12

20.
 If accurate, please add a reference to the Buffer and Floor in the following statement: “[t]he calculated
price takes into account the applicable Cap or Upside Participation Rate and the Downside Participation Rate.”

 RESPONSE: The
portion of that subsection has been removed, but the Company has correctly listed the downside limits in similar disclosures that remain in the prospectus.

Strategy Renewals and Reallocations

21.
 Add a third bullet point explaining what happens if the investor does not reallocate and the same Indexed
Strategy is not available for a new Term.

 RESPONSE: Because the same rule is not used for all strategies, the Company made the
requested revision after the paragraph beneath the bullet points instead of adding a third bullet point.

22.
 Please make the entire paragraph that begins “[y]ou cannot reallocate your value among Indexed Strategies
during a Term” more prominent.

 RESPONSE: The Company has made the requested revision.

Right to Cancel

23.
 The Company states that for purposes of the refund amount if an investor exercises his/her right to cancel,
“[n]o adjustment will be made for the Daily Value Percentage.” Please reconcile this with the statement under Right to Cancel (Free Look) section later in the prospectus that “[i]f the Account Value includes the value of an Indexed
Strategy, that Strategy value will reflect the applicable Daily Value Percentage.”

 RESPONSE: The Company notes that phrase
“no adjustment will be made for the Daily Value Percentage” applies only in states where the refund amount is equal to the Purchase Payments. The Company has made revisions in multiple parts of the prospectuses to clarify this point.

Risk Factors

 Loss of Principal Related to
Market Value Adjustment

24.
 Please note in this risk factor that the Market Value Adjustment can adversely impact the effect of amounts
taken from the contract even if index performance has been positive.

 RESPONSE: The Company has made the requested revision.

Effect of All Withdrawals

25.
 In this risk factor, please also include a separate paragraph discussing the risks arising from the deduction
of advisory fees from contract value (i.e., explain that this deduction will reduce the Death Benefit and may be subject to federal and state income taxes and a 10% federal penalty tax if federal or state authorities determine, notwithstanding the
private letter ruling issued to the Company, that these deductions are taxable).

  Commissioners

June 21, 2022

 Page 7 of 12

 RESPONSE: The Company has enhanced the disclosures in this section.

Unavailable Indexed Strategies

26.
 In the first bullet discussing the default allocations, please specify the Positive and Negati