Correspondence 0001104659-24-091498 from PROTECTIVE VARIABLE ANNUITY SEPARATE ACCOUNT (CIK 0000914245)
PROTECTIVE VARIABLE ANNUITY SEPARATE ACCOUNT (CIK 0000914245)
Date: Aug. 21, 2024 · CIK: 0000914245 · Accession: 0001104659-24-091498
AI Filing Summary & Sentiment
File numbers found in text: 333-237747, 811-08108
Letter
Lindsay Thorpe, Counsel
Protective Life Insurance Company
Writer’s Direct Number: (205) 898-7409
Facsimile Number: (205) 268-3597
Toll-Free Number: (800) 627-0220
E-mail: lindsay.thorpe@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. 11 to the Registration Statement on Form N-4
File Nos. 333-237747 & 811-08108
Ms. White:
On behalf of Protective Life Insurance Company (the “Company”) and on behalf of Protective Variable Annuity Separate Account (the “Account”), we have filed this letter as correspondence via EDGAR to the above referenced Post-Effective Amendment No. 11 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 the comment received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on August 19, 2024.
PROSPECTUS (Protective Investors Benefit Advisory Variable Annuity 333-237747)
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.
2801 US-280 • Birmingham, AL 35223 | (205) 268-1000 | protective.com
Ms. White
August 21, 2024
Page
* * * * *
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 205-898-7409. We greatly appreciate the Staff's efforts in assisting the Company with this filing.
Sincerely,
/s/ Lindsay Thorpe
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CORRESP
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Lindsay Thorpe, Counsel
Protective Life Insurance Company
Writer’s Direct Number: (205) 898-7409
Facsimile Number: (205) 268-3597
Toll-Free Number: (800) 627-0220
E-mail: lindsay.thorpe@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. 11 to the Registration
Statement on Form N-4
File Nos. 333-237747 & 811-08108
Ms. White:
On behalf of Protective Life
Insurance Company (the “Company”) and on behalf of Protective Variable Annuity Separate Account (the “Account”),
we have filed this letter as correspondence via EDGAR to the above referenced Post-Effective Amendment No. 11 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 the comment received from the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) on August 19, 2024.
PROSPECTUS (Protective Investors Benefit Advisory
Variable Annuity 333-237747)
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.
2801 US-280 • Birmingham, AL 35223
| (205) 268-1000 | protective.com
Ms. White
August 21, 2024
Page
2
* * * * *
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 205-898-7409. We greatly appreciate the Staff's efforts in assisting the Company with this
filing.
Sincerely,
/s/ Lindsay Thorpe
Lindsay Thorpe
Counsel
2