SEC Company Response from TRANSAMERICA ASSET ALLOCATION VARIABLE FUNDS (CIK 0001018953) — Apr 13, 2005
TRANSAMERICA ASSET ALLOCATION VARIABLE FUNDS (CIK 0001018953)
Date: April 13, 2005 · CIK: 0001018953 · Accession: 0000929638-05-000097
AI Filing Summary & Sentiment
File numbers found in text: 811-07717, 811-8264
Letter
April 13, 2005 VIA EDGAR Alison White, Esq. Securities and Exchange Commission Division of Investment Management Judiciary Plaza 450 Fifth Street, N.W. Washington, D.C. 20549 Diversified Investors Variable Funds Registration Statement on Form N-4 (File Nos. 33-73734 and 811-8264)
Re: Diversified Investors Strategic Variable Funds Registration Statement on Form N-3 (File Nos. 33-08543 and 811-07717)
Dear Ms. White:
This letter relates to the Diversified Investors Strategic Variable Funds and the Diversified Investors Variable Funds, both separate accounts established by Transamerica Financial Life Insurance Company under New York Insurance Law (the "Registrants"), and follows up on telephone conversations I had with you on Monday and this morning.
In response to one of your comments on the Registrants' filings made under Rule 485(a)(1) on March 1, 2005, and consistent with our discussions, each of the Registrants filed yesterday, under Rule 485(a)(1), amendments to their respective registration statements to provide the additional disclosure you requested. As we discussed, on behalf of the Registrants, we hereby request that the Staff accelerate the effectiveness of the amendments to April 29, 2005.
Thank you for your consideration of this request. If there is anything I can do to facilitate or expedite the review process, please let me know. Please call me at (617) 951-8567 with any questions or comments on the filing, or if I can otherwise be of assistance.
Sincerely,
/s/ Paul B. Raymond
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<DOCUMENT>
<TYPE>CORRESP
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<TEXT>
Bingham McCutchen LLP
150 Federal Street
Boston, MA 02110
April 13, 2005
VIA EDGAR
Alison White, Esq.
Securities and Exchange Commission
Division of Investment Management
Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549
Re: Diversified Investors Strategic Variable Funds
Registration Statement on Form N-3
(File Nos. 33-08543 and 811-07717)
Diversified Investors Variable Funds
Registration Statement on Form N-4
(File Nos. 33-73734 and 811-8264)
Dear Ms. White:
This letter relates to the Diversified Investors Strategic Variable
Funds and the Diversified Investors Variable Funds, both separate accounts
established by Transamerica Financial Life Insurance Company under New York
Insurance Law (the "Registrants"), and follows up on telephone conversations I
had with you on Monday and this morning.
In response to one of your comments on the Registrants' filings made
under Rule 485(a)(1) on March 1, 2005, and consistent with our discussions, each
of the Registrants filed yesterday, under Rule 485(a)(1), amendments to their
respective registration statements to provide the additional disclosure you
requested. As we discussed, on behalf of the Registrants, we hereby request that
the Staff accelerate the effectiveness of the amendments to April 29, 2005.
Thank you for your consideration of this request. If there is anything
I can do to facilitate or expedite the review process, please let me know.
Please call me at (617) 951-8567 with any questions or comments on the filing,
or if I can otherwise be of assistance.
Sincerely,
/s/ Paul B. Raymond
Paul B. Raymond
cc: Robert F. Colby, Esq.
Roger P. Joseph, Esq.
</TEXT>
</DOCUMENT>