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PIA VARIABLE ANNUITY ACCOUNT I

 Christopher E. Palmer

 +1 202 346 4253

 cpalmer@goodwinlaw.com

 Goodwin Procter LLP

 1900 N Street, NW

 Washington, DC 20036

 goodwinlaw.com

+1 202 346 4000

 November 30, 2023

VIA EDGAR

 Elizabeth Bentzinger

U.S. Securities and Exchange Commission

 Division of Investment
Management

 100 F Street, NE

 Washington, DC 20549

Re:
 The Penn Insurance and Annuity Company

PIA Variable Annuity Account I

Initial Registration Statement on Form N-4

File Nos. 333-273819; 811-08720

Dear Ms. Bentzinger:

 This letter responds to comments
that you provided in a letter dated October 6, 2023, with respect to your review of an initial registration statement on Form N-4 (the “Registration Statement”) filed on behalf of The Penn
Insurance and Annuity Company (the “Company”) and its separate account, PIA Variable Annuity Account I (the “Registrant”) for the Deferred Variable Annuity Contract (the “Contract”).

Set forth below are the comments of the SEC staff along with the responses thereto by the Company and the Registrant. Undefined capitalized terms used below
have the same meaning as in the Registration Statement. The Company and the Registrant are filing today a pre-effective amendment to the Registration Statement (the “Amendment”) to reflect the
responses to the comments.

 General

1.
 Comment: Please confirm that all missing information, including the financial statements
and all exhibits, will be filed in a pre-effective amendment to the registration statement. We may have further comments when you supply the omitted information.

Response: The Company confirms that the financial statements, all exhibits, and any additional missing information will be filed
in a second pre-effective amendment to the registration statement after receiving any comments to the first pre-effective amendment filed today.

2.
 Comment: Please clarify supplementally whether there are any types of 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 Contract.

 PIA Variable Annuity Account I

Deferred Variable Annuity Contract

 November 30, 2023

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 Response: The Company confirms that there are no guarantees or support
agreements with third parties to support any contract features or benefits and that it will be solely responsible for any benefits or features associated with the Contract.

3.
 Comment: Where a comment is made regarding the disclosure in one location, it is
applicable to all similar disclosure appearing elsewhere in the registration statement, including the summary prospectus. Capitalized terms have the same meaning as in the registration statement unless otherwise indicated.

Response: As applicable, the Company has made corresponding changes throughout the registration statement.

4.
 Comment: Please reconcile the name of the Contract described in the prospectus (the
Deferred Variable Annuity Contract) with the contract name listed in the EDGAR contract ID (Individual Variable and Fixed Deferred Annuity).

Response: The Company has reconciled the contract name listed in the EDGAR contract ID with the name of the Contract described
in the prospectus.

 PROSPECTUS

 Definitions

5.
 Comment: All riders offered under the Contract must be purchased at issue and therefore
the Rider Effective Date is the Contract Date. Please remove the term Rider Effective Date from the prospectus in accordance with plain English principles. Rule 421 of the Securities Act of 1933 (the “Securities Act”).

 Response: The Company has revised the disclosure as requested and made corresponding revisions throughout
the prospectus and summary prospectus.

 Important Information You Should Consider About the Deferred Variable Annuity Contract

6.
 Comment: Please remove the second, third, and fourth sentence in the Transaction Charges
section of the Fees and Expenses table. This disclosure is neither permitted nor required by Item 2 of Form N-4. See General Instruction C.3.(b) of Form N-4.

 Response: The Company has revised the disclosure as requested.

 PIA Variable Annuity Account I

Deferred Variable Annuity Contract

 November 30, 2023

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 3

7.
 Comment: In the Ongoing Fees and Expenses section of the table, please remove
“None” from the minimum optional benefit charge in the table and disclose the current fee for the least expensive optional benefit available for an additional charge (i.e., the Enhanced Death Benefit Rider’s 0.35% fee). Instruction
2(c)(i)(F) to Item 2 of Form N-4.

 Response: The Company has
revised the disclosure as requested.

8.
 Comment: In the Restrictions – Optional Benefits section of the table, please revise
the first bullet to more clearly state that if an investor selects an optional benefit, the investor will not be permitted to invest in the Short-Term Fixed Account. Please make corresponding changes to the first paragraph in the Optional Benefit
Risks discussion on page 19.

 Response: The Company has revised the disclosure as requested and made
corresponding revisions throughout the prospectus and summary prospectus.

9.
 Comment: In the Conflicts of Interest - Exchanges section of the table, please lowercase
both references to “Contract” in the second sentence to ensure investors are cautioned on the risks of exchanges prior to purchasing the Contract.

Response: The Company has revised the disclosure as requested and made corresponding revisions to the summary prospectus.

Overview of the Deferred Variable Annuity Contract

10.
 Comment: Please revise the last sentence of the Surrenders and Withdrawals discussion on
page 12 to make clear that withdrawals, including Required Minimum Distributions, could significantly reduce the standard death benefit in addition to the guaranteed benefits, and that withdrawals could terminate guaranteed benefits.

 Response: The Company has revised the disclosure as requested.

11.
 Comment: Please remove the statement in the Optional Benefit Riders discussion that an
investor should check with their financial professional to determine the optional benefits that may currently be available to them. Please describe all material features of the Contract, including all state and distribution channel variations, in
the prospectus. Please remove similar disclosure on page 41 of the prospectus.

 Response: The Company has
revised the disclosure as requested and made corresponding revisions throughout the prospectus and summary prospectus.

 PIA Variable Annuity Account I

Deferred Variable Annuity Contract

 November 30, 2023

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 Table of Fees and Expenses

12.
 Comment: The footnote accompanying the Maximum Expense Examples states that the expenses
assume that the Accumulation Income Rider and the Enhanced Death Benefit Rider are purchased with maximum rider charges of 2.50%. Please reconcile this disclosure with the Annual Contract Expenses section of the Fee Table, which states that the
Accumulation Income Rider charge is 2.00% and the Enhanced Death Benefit Rider charge is 0.75%, resulting in a combined charge for both riders of 2.75%. Moreover, the Enhanced Death Benefit Rider may be elected with the Guaranteed Income Rider,
which has a maximum charge of 2.50%. Therefore, the Maximum Expense Examples should be revised to assume that the Enhanced Death Benefit Rider and Guaranteed Income Rider are purchased with the most expensive combination of maximum rider charges
(3.25%).

 Response: The Company has revised the disclosure as requested and made corresponding revisions
throughout the prospectus and summary prospectus.

 How Do I Change the Contract’s Investment Allocations?

13.
 Comment: Please describe with specificity the Company’s policies, procedures, and
restrictions for deterring frequent transfers of Contract Value among the Variable Investment Options, including a description of any restrictions on the volume or number of transfers that may be made within a given time period, any minimum holding
period that is imposed before a transfer may be made from one Variable Investment Option to another, any restrictions imposed on transfer requests submitted by overnight delivery, electronically, or via facsimile or telephone, and any right by the
Company to reject, limit, delay, or impose other conditions on transfers or to terminate or otherwise limit Contracts based on a history of frequent transfers among Variable Investment Options, including the circumstances under which such right will
be exercised. Item 8(f)(4) of Form N-4.

 Response: The Company has
revised the disclosure to reference the Contract provision that limits the number of transfers permitted in a calendar month and year and clarified that it retains the right to restrict the frequency of transfers in accordance with this provision in
the future. The Company notes that it added disclosure about its policies and procedures regarding transfer activity limitations and restrictions, as well as the types of restrictions that may be imposed on transfer requests in 2022 in response to a
Staff comment on a similar filing for a different registrant. The Company respectfully declines to revise the disclosure further as it believes more specificity would make it easier for investors to evade its policies and procedures designed to
discourage excessive trading and market timing activities.

 PIA Variable Annuity Account I

Deferred Variable Annuity Contract

 November 30, 2023

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 What Are the Fees and Charges Under the Contract?

14.
 Comment: In the second paragraph on page 28, please disclose the default option if an
investor does not choose to have the surrender charge deducted from the amount withdrawn or from the remaining Contract Value.

Response: The Company has revised the disclosure as requested.

15.
 Comment: In the narrative preceding the Schedule of Surrender Charges, please remove the
disclosure stating that the surrender charge percentage varies by the Base Contract Option as there is only one such option under the Contract.

Response: The Company has revised the disclosure as requested.

16.
 Comment: Please disclose what is provided in consideration for the Annual Contract
Administration Charge. Item 7(a) of Form N-4.

 Response: The
Company has revised the disclosure as requested.

 What are the Supplemental Riders and Benefits that are Available?

17.
 Comment: Please provide one or more examples illustrating the complete operation of each
benefit, including the Guaranteed Income Rider, Accumulation Income Rider, Enhanced Death Benefit Rider, and Guaranteed Minimum Accumulation Benefit, in a clear, concise, and understandable manner. In these examples, please reflect the impact of
Purchase Payments, Early Access Withdrawals, and Excess Withdrawals on the applicable benefit base and other calculations under each rider, such as the Guaranteed Growth Amount.

Response: The Company has revised the disclosure as requested.

18.
 Comment: Please confirm supplementally that the rates and assumptions reflected in the
examples throughout the propsectus are reasonable in light of current and anticipated market conditions and based on rates and assumptions that the Company anticipates offering at the time the Contract is first issued.

Response: The Company confirms that the rates and assumptions reflected in the examples throughout the propsectus are reasonable
in light of current and anticipated market conditions and based on rates and assumptions that the Company anticipates offering at the time the Contract is first issued.

 PIA Variable Annuity Account I

Deferred Variable Annuity Contract

 November 30, 2023

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 Enhanced Death Benefit Rider

19.
 Comment: In the Important Information about the Rider discussion, please disclose that the
rider provides a contingent guarantee that may never come into effect because the Enhanced Death Benefit may never exceed the Standard Death Benefit. Please also reconcile the fourth and fifth bullets, which appear to be addressing the same point
with regard to when the enhanced amount is no longer payable.

 Response: The Company has revised the
disclosure as requested.

20.
 Comment: In the Important Information about the Rider discussion’s eighth bullet,
please state that Required Minimum Distributions (“RMDs”) could significantly reduce the values under the rider, perhaps by more than the amount of the withdrawal, and could terminate the rider and the Contract. Please also disclose that
an investor should not purchase the rider if they plan to take RMDs from the Contract. Please make clear that RMDs may reduce the Enhanced Death Benefit rider’s benefits and terminate the rider in the Restrictions – Optional Benefits
section of the table on page 10 of the prospectus, the Optional Benefit Riders discussion on page 13, the Optional Benefit Risks discussion on page 19, and in the benefit table on page 40 of the prospectus.

Response: The Company has revised the disclosure related to the possibility that RMDs could significantly reduce the values
under the Enhanced Death Benefit Rider, perhaps by more than the amount of the withdrawal, and could terminate the Enhanced Death Benefit Rider and the Contract as requested and has made corresponding changes throughout the prospectus and summary
prospectus. The Company respectfully declines to advise investors on whether or not they should purchase the rider.

 Guaranteed Income Rider and
Accumulation Income Rider

 Benefit Overview

21.
 Comment: In the first sentence of the Benefit Overview section for the Guaranteed Income
Rider and the Accumulation Income Rider, please clearly explain in accordance with plain English principles the type of guarantee each rider is designed to provide (i.e., without simply stating that the rider is an optional benefit that provides a
Living Benefit Guarantee or a Lifetime Withdrawal Guarantee). See, for example, the Benefit Overview section of the Guaranteed Minimum Accumulation Rider discussion, which states that the rider is designed to provide a minimum Contract Value at the
end of the Accumulation Benefit Period.

 Please make clear that, at least with respect to the Accumulation Income Rider
and the Lifetime Withdrawal Guarantee under the Guaranteed Income Rider, the rider promises a minimum amount that may be withdrawn periodically from the Contract over a specified period regardless of the performance of the Variable Investment
Options if certain conditions are met. With respect to the Standard Withdrawal Benefit under the Guaranteed Income Rider, please clearly explain

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Deferred Variable Annuity Contract

 November 30, 2023

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what guarantee is being provided by the Company (i.e., when might the Company make payments to an investor from its general account) as the rider terminates if Contract Value is reduced to zero.

 Response: In response to the first two sentences, the Company has revised and added disclosure regarding the type of
guarantee each rider is designed to provide. In response to the third sentence, the Company has added the requested disclosure. In response to fourth sentence, the Company has revised the disclosure regarding the Standard Withdrawal Benefit but
notes that the Standard Withdrawal Guarantee does not necessarily terminate if the Contract Value is reduced to zero.

22.
 Comment: Please prominently disclose that the Company will impose surrender charges on any
withdrawal taken under the Guaranteed Income Rider or the Accumulation Income Rider, as applicable, including withdrawals within the Guaranteed Annual Withdrawal Amount. Please provide corresponding prominent disclosure whenever discussing
withdrawals in the rider discussion as well as in the Restrictions – Optional Benefits section of the table on page 10 of the prospectus, the Optional Benefit Rider