Correspondence 0001104659-24-091496 from PROTECTIVE VARIABLE ANNUITY SEPARATE ACCOUNT (CIK 0000914245)
PROTECTIVE VARIABLE ANNUITY SEPARATE ACCOUNT (CIK 0000914245)
Date: Aug. 21, 2024 · CIK: 0000914245 · Accession: 0001104659-24-091496
AI Filing Summary & Sentiment
File numbers found in text: 333-261426, 333-261830, 811-08108, 811-08537
Letter
BRANDON J. CAGE
Vice President and Managing Counsel
Writer’s Direct Number: (205) 268-1889
Facsimile Number: (205) 268-3597
Toll-Free Number: (800) 627-0220
E-mail: brandon.cage@protective.com
August 21,
Via EDGAR and E-mail
Ms. Alison White
Senior Counsel
Disclosure Review Office 2
Division of Investment Management
U.S. Securities and Exchange Commission
100 F. Street, N.E.
Washington, D.C.
Re: Protective Life Insurance Company
Protective Variable Annuity Separate Account 811-08108
Post-Effective Amendment No. 7 to the Registration Statement on Form N-4
File Nos. 333-261426 & 811-08108
Protective Life and Annuity Insurance Company
Variable Annuity Account A of Protective Life 811-08537
Post-Effective Amendment No. 3 to the Registration Statement on Form N-4
File Nos. 333-261830 & 811-08537
Ms. White:
On behalf of Protective Life Insurance Company, Protective Life and Annuity Insurance Company (collectively the “Company”) and on behalf of Protective Variable Annuity Separate Account and Variable Annuity Account A of Protective Life (collectively the “Account”), we have filed this letter as correspondence via EDGAR to the above referenced Post-Effective Amendments to the Form N-4 Registration Statement (the “Amendment”) for certain flexible premium deferred variable and fixed annuity contracts (the “Contracts”). This letter provides the Company’s response to comment received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on August 19, 2024.
For the Staff’s convenience, each Staff comment is set forth in full below, followed by the Company’s response.
US-280 • Birmingham, AL 35223 | (205) 268-1000 | protective.com
Ms. White
August 21, 2024
Page 2
PROSPECTUS (Aspirations 333-261426 and Aspirations NY 333-261426)
1. Staff Comment: Please disclose all material financial intermediary variations, in the Prospectus.
Response: We will add a new appendix to the prospectus that discloses all material financial intermediary variations (if any) consistent with the Staff’s comment when we file the post-effective amendment for annual updates, effective May 1, 2025.
* * * * *
We believe that the foregoing responds to the Commission Staff comment. We respectfully request that the Staff review as soon as possible.
If you have any questions regarding this letter, please contact me at 205-268-1889. We greatly appreciate the Staff's efforts in assisting the Company with this filing.
Sincerely,
/s/ Brandon J.
Cage
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CORRESP
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filename1.htm
BRANDON J. CAGE
Vice President and Managing Counsel
Writer’s Direct Number: (205) 268-1889
Facsimile Number: (205) 268-3597
Toll-Free Number: (800) 627-0220
E-mail: brandon.cage@protective.com
August 21,
2024
Via EDGAR
and E-mail
Ms. Alison
White
Senior Counsel
Disclosure Review
Office 2
Division of Investment
Management
U.S. Securities
and Exchange Commission
100 F. Street,
N.E.
Washington, D.C.
20549
Re:
Protective Life Insurance Company
Protective Variable Annuity Separate Account 811-08108
Post-Effective Amendment No. 7 to the Registration
Statement on Form N-4
File Nos. 333-261426 & 811-08108
Protective Life and Annuity Insurance Company
Variable Annuity Account A of Protective Life
811-08537
Post-Effective Amendment No. 3 to the Registration
Statement on Form N-4
File Nos. 333-261830 & 811-08537
Ms. White:
On
behalf of Protective Life Insurance Company, Protective Life and Annuity Insurance Company (collectively the “Company”) and
on behalf of Protective Variable Annuity Separate Account and Variable Annuity Account A of Protective Life (collectively the “Account”),
we have filed this letter as correspondence via EDGAR to the above referenced Post-Effective Amendments to the Form N-4 Registration
Statement (the “Amendment”) for certain flexible premium deferred variable and fixed annuity contracts (the “Contracts”).
This letter provides the Company’s response to comment received from the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) on August 19, 2024.
For
the Staff’s convenience, each Staff comment is set forth in full below, followed by the Company’s response.
2801
US-280 • Birmingham, AL 35223 | (205) 268-1000 | protective.com
Ms. White
August 21, 2024
Page 2
PROSPECTUS (Aspirations
333-261426 and Aspirations NY 333-261426)
1. Staff
Comment: Please disclose all material financial intermediary variations, in the Prospectus.
Response: We will add a new appendix to the prospectus that discloses all material financial intermediary
variations (if any) consistent with the Staff’s comment when we file the post-effective amendment for annual updates, effective
May 1, 2025.
* * * * *
We
believe that the foregoing responds to the Commission Staff comment. We respectfully request that the Staff review as soon as possible.
If
you have any questions regarding this letter, please contact me at 205-268-1889. We greatly appreciate the Staff's efforts in assisting
the Company with this filing.
Sincerely,
/s/ Brandon J.
Cage
Brandon J. Cage
Vice President and Managing Counsel
2