SecProbe.io

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THOMAS C. BILELLO

Vice President and Associate General Counsel

Law Department

(949) 420-7078 Telephone

(949) 219-3706 Facsimile

Thomas.Bilello@PacificLife.com

February 1, 2023

Yoon Choo

Senior Counsel

Office of Insurance Products

Division of Investment Management

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, DC 20549-0506

    Re:
    Pacific Life Insurance
    Company

    Pacific Select Exec Separate
    Account – File No. 811-05563

    Initial Registration Statement and on Form N-6

    Pacific Legacy SVUL - File No. 333-267433

Dear Ms. Choo:

On behalf of Pacific Life Insurance Company (“Pacific Life”)
and Pacific Select Exec Separate Account of Pacific Life (811-05563). Set forth below are responses to Staff comments received on November
14, 2022, in connection with the above referenced Initial Registration Statement on Form N-6, filed September 15, 2022.

PROSPECTUS

GENERAL

 1. Please confirm supplementally that all missing information and all exhibits
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.

Response: We herby confirm that any missing information
and any additional exhibits will be included and filed via a pre-effective amendment to this Registration Statement.

 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. Please ensure that
corresponding changes are made to all similar disclosure.

Response: Duly noted.

 3. Please clarify supplementally whether there are any guarantees or support
agreements with third parties to support any policy features or benefits, or whether the Company will be solely responsible for any benefits
or features associated with the Policy issued by the Separate Account.

Response: Other than reinsurance contracts, we hereby
confirm that there are no third-party support agreements; the Company is primarily responsible for paying out any guarantees associated
with the Policies.

 4. Please be aware that the compliance date for the requirement to use the
Inline eXtensible Business Reporting Language (XBRL) format for the submission of certain required disclosures in the variable contract
statutory prospectus is January 1, 2023. Filings made on or after January 1, 2023 will be required to comply with these requirements.
[General Instruction C.3.(h).]

Response: We are aware of the compliance date for XBRL
formatting and will ensure the necessary disclosures comply with these requirements.

PROSPECTUS

Table of Contents

 5. In the electronic versions of the Prospectuses and SAI, please add hyperlinks
to the headings and subheadings in the Tables of Contents to link directly to the relevant sections in the document.

Response: We will add hyperlinks or
other means of facilitating access to that information through equivalent methods or technologies. Please note, we will not be utilizing
summary prospectuses at this time.

Special Terms

 6. Please explain in the defined term “Account Additions” what
these are (e.g., premiums and additional credits).

Response: We made the requested modification.

 7. The definition of “Account Deductions” states that deductions
are taken proportionately from the Fixed and Variable Account Values, but that the Company makes available other ways to make deductions.
Please disclose the other ways to make deductions in an appropriate location in the Prospectus and include a cross reference to the relevant
discussion in the definition.

Response: We made the requested modification.

 8. In the definition of “Additional Credit,” please add that
any such credit may be applied beginning on the 11th Policy Anniversary.

Response: We made the requested modification.

 9. Please revise the definition of “Basic Face Amount” and/or
 “Face Amount” to better distinguish the intended substantive difference between the terms or eliminate one of the terms.

Response: For this Policy, an additional
Face Amount may be provided by the Estate Preservation Rider. The Face Amount term is necessary to ensure consumers understand the difference
in death benefits provided by the Policy and additional Riders. We respectfully decline to make the requested modification.

 10. Please revise the definition of “Basic Life
Coverage Layer” and/or “Coverage Layer” to better distinguish the intended substantive difference between the terms
or eliminate one of the terms.

Response: The
Coverage Layer term is intentionally included to provide us with flexibility to add riders that provide additional coverage in the future.
We respectfully decline to make the requested modification.

 11. In the definition of “Loan Account Value,” please add at the
end of the third sentence, “during which a Loan Account is outstanding” or a similar statement.

Response: We made the requested modification.

 12. Please delete the second sentence of the definition of “Riders,”
since no currently available Rider offers additional life insurance coverage.

Response: The Estate Preservation
Rider offers a Rider Face Amount during the first four years of the Policy. We have revised the last sentence to remove the reference
to increasing the coverage.

 13. Please clarify in the definition of “Surrender Charge” that
the charge will apply during the first 20 years of any Basic Life Coverage Layer added to the Policy.

Response: We made the requested modification.

Important Information You Should Consider About the
Policy

 14. Please confirm supplementally that the key information table cross-references
in the electronic version of the Prospectus will link directly to the location in the statutory Prospectus where the subject matter is
discussed in greater detail, or will provide a means of facilitating access to that information through equivalent methods or technologies.
[Instruction 1(b) to Item 2.]

Response: We confirm that we will comply with the requirements
of the above referenced instruction.

Fees and Expenses

—Transaction Charges

 15. The Prospectus does not disclose a charge for Risk Class changes and the
optional Riders do not allow for requests to increase benefits. Please remove the references to risk class

changes and for requests to
increase benefits under an optional Rider in this section. Please add a reference to charges imposed to exercise certain optional riders.

Response: We made the requested modification.

Risks

—Not a Short-Term Investment

 16. Please add a statement that no withdrawals may be made during the first
year of the Policy.

Response: We made the requested modification.

— Contract Lapse

 17. Please address the following comments in this section and under Principal
Risks of Investing in the Policy—Policy Lapse:

 a. revise the discussion to include reference to the Short-Term No-Lapse
Guarantee Rider, explain that the Policy will not lapse if the Rider conditions are satisfied and provide a cross reference to the relevant
discussion in the Prospectus;

 b. change “no death benefit will be paid” to “no death
benefit or other benefits will be paid”; and

 c. disclose that the Insureds must apply for reinstatement and that there
is no guarantee that reinstatement will be approved or reapproved in the same Risk Class.

Response:

For the comment a., not all policies
are eligible for the Short-Term No-Lapse Guarantee Rider. We have included a cross-reference in this section and the Principal Risks
of Investing in the Policy – Policy Lapse section to the Short-Term No-Lapse Guarantee Rider in the OTHER BENEFITS AVAILABLE
UNDER THE POLICY section in this prospectus.

For comment b., we made the requested
modification to this section and under Principal Risks of Investing in the Policy – Policy Lapse.

For comment c., we made the requested
modification to this section and to Principal Risks of Investing in the Policy – Policy Lapse to include that a reinstatement
must be applied for and there is no guarantee that it will be approved.

With regards to the Risk Class, if
the reinstatement application is approved, the same Risk Classes will be used and are not changed. We have included this clarification
as well.

Restrictions

—Investments

 18. Please add that there is a $25 fee per transfer in excess of 12 transfers
per Policy Year. [Instruction 4(a) to Item 2.]

Response: We made the requested modification.

—Optional Benefits

 19. Please address the following comments:

 a. disclose that some optional Riders must be elected at Policy issue, may
be subject to conditions to exercise or underwriting, and that your election of certain optional Riders may result in restrictions on
some Policy benefits [Instruction 4(b) to Item 2];

 b. if availability of some Riders varies by selling broker dealer, please
so state in each location that states that Riders may not be available in all states; and

 c. since the Prospectus does not describe any restrictions
on Investment Options, please delete the statement that “[c]ertain optional benefits limit or restrict the Investment Options that
you may select under the Contract.”

Response: We have made the requested changes
for the first and third comments. For the second comment, the disclosure in question does not refer to any intermediary-specific variation
and is only related to state availability.

Overview of the Policy

Purpose

 20. Please tailor the disclosure in this section to reflect that the Policy
covers the lives of two Insureds.

Response: We made the requested modification.

 21. In the last sentence of the section, please add “and Death Benefit
Qualification Test” immediately after “Death Benefit Option.”

Response: We made the requested modification.

Premiums

 22. Please revise the discussion of Policy lapse in this section and under
How Premiums Work—Planned Premium Payments in light of the fact that the Short-Term No-Lapse Guarantee Rider is a standard
feature of the Policy.

Response: The Rider may not be available to all Insureds
and should be considered a standard feature available to all. We respectfully decline to make the requested modification.

Policy Features

—Death Benefit

 23. The disclosure states that “[t]he death benefit proceeds equal the
death benefit plus any additional benefit provided by a rider less any outstanding loan or unpaid Policy charges.” No additional
benefits are provided by any Rider in connection with the Death Benefit. Please remove the reference.

Response: If paid, the death benefit included in the Estate
Preservation Benefit Rider would be added to the Death Benefit Proceeds. We respectfully decline to make the requested modification.

 24. The disclosure states that “Policy charges vary
depending on which Death Benefit Option is selected.” If Policy charges also vary depending on which Death Benefit Qualification
Test is selected, please so indicate in the disclosure.

Response: We made the requested modification.

—Surrender

 25. Please add “or benefits” immediately after “no life
insurance coverage” in the third sentence of this paragraph.

Response: We made the requested modification.

 26. Please consider adding to the fourth sentence that tax consequences including
a possible tax penalty if surrendered before age 59½.

Response: We have changed the last
sentence to direct the policy owner to their tax advisor for information on any potential tax impact a surrender may have.

Fee Tables

Transaction Fees

—Maximum Sales Charge Imposed on Premiums (Load)

 27. The first note to appear under Transaction Fees is Note 3. Please
renumber the notes sequentially starting with Note 1.

Response: We made the requested modification.

—Maximum surrender charge

 28. In Note 1, please consider adding a cross reference to the discussion
of the Surrender Charge in Withdrawals, Surrenders and Loans—Surrendering Your Policy.

Response: We made the requested modification.

Periodic Charges Other Than Fund Operating Expenses

 29. Please consider adding that the maximum charge under Administrative charge
is also the current charge.

Response: We made the requested modification.

 30. Please remove the Policy Split Option Rider from this table. This transactional
charge is covered under The Transaction Fees table.

Response: We made the requested modification.

 31. Note 4 to the table states “[t]he Coverage charge on a current basis
only applies for the first 10 years of each Coverage Layer.” Please disclose how the Coverage charge will be calculated after the
first 10 years of a Coverage Layer or provide a cross reference to the relevant discussion in the Prospectus.

Response: We made the requested modification.

 32. Note 6 which applies to all Optional Benefit Charges states that “[r]ider
charges are based on the Age and Risk Class of the person insured under the Rider on the effective date of the Rider.” If accurate,
please revise so that the statement applies only to the Estate Preservation Rider.

Response: We made the requested modification.

Policy Basics

Owners, the Insureds, and Beneficiaries

—Owners

 33. The disclosure states that “[y]ou can own a Policy by yourself or
with someone else.” Special Terms defines “Owner” as “the person named on the application who makes the
decisions about the Policy.” The preceding disclosure is identical to the disclosure that the Company uses for its policies that
cover a single insured. Please tailor the ownership disclosure throughout to reflect a Policy that covers two Insureds. For example, please
add that if the Policy is owned by one Owner, the Owner can make all decisions regarding the Policy and its benefits for both Insureds.
Please disclose whether the application requires that both Insureds be affirmatively identified by the applicants as Owners or whether
both Insureds are deemed Owners, unless the application specifies a different person as the Owner. Also, disclose what happens when the
application does not indicate an Owner(s).

Response: The Owner role is independent
of the insured, regardless of if a policy has one Insured or two Insureds and the Owner does not have to be an Insured. Our current Owners
disclosure accurately describes the role, and we respectfully decline to make the requested modification. We have added disclosure to
address what happens when an owner is not indicated on the application.

—The Insured

 34. If the Company intends to use simplified underwriting or other underwriting
methods that would cause healthy individuals to pay higher cost of insurance rates than they would pay under a substantially similar policy
that is offered by the Company using different underwriting methods, state that the cost of insurance rates are higher for healthy individuals
when this method of underwriting is used than under the substantially similar policy. [Instruction 2 to Item 7 (a).]

Response: We have updated the disclosure
to clarify that only one type of underwriting is available.

Illustrations

 35. Please add “historical or” immediately before “a hypothetical
gross rate of return” in the third bullet point.

Response: FINRA guidelines do not require
illustrations to use historical fund performance and we believe including it may cause confusion. We respectfully decline to make the
requested modification.

Telephone and Electronic Transactions

 36. An investor may authorize the Company to accept telephone and electronic
instructions for certain transactions, including initiating loans. Can loan increases or repayments also

 be authorized in this manner?
If so, please revise the disclosure.

Response: Loan increases are considered
within the existing “Initiate Loans” bullet. Electing Telephone and Electronic Transactio