SEC Company Response from TRANSAMERICA ASSET ALLOCATION VARIABLE FUNDS (CIK 0001018953) — Apr 20, 2022
TRANSAMERICA ASSET ALLOCATION VARIABLE FUNDS (CIK 0001018953)
Date: April 20, 2022 · CIK: 0001018953 · Accession: 0001193125-22-110773
AI Filing Summary & Sentiment
File numbers found in text: 333-08543
Letter
Transamerica Asset Allocation Variable Funds
Home Office:
Harrison, NY
Administrative Office:
6400 C Street SW
Cedar Rapids, IA 52499
April 20, 2022
[VIA EDGAR]
Mr. Christopher Bellacicco, Esq.
U.S. Securities and Exchange Commission
100 F Street NE
Washington, DC 20549-0506
Re: Transamerica Financial Life Insurance Company
Transamerica Variable Funds: Form N-4 Registration Statements (File No. 33-73734)
Transamerica Asset Allocation Variable Funds: Form N-3 Registration Statements
(File No. 333-08543)
Mr. Bellacicco:
This letter responds to comments that you provided via phone call on April 19, 2022, with respect to the above-referenced filings for the separate accounts of Transamerica Financial Life Insurance Company (“TFLIC”) relating to the Transamerica Variable Funds and Transamerica Asset Allocation Variable Funds variable annuities.
For your convenience, I have restated those comments below, and followed each comment with our response.
I. Transamerica Variable Funds/ Transamerica Asset Allocation Variable Funds Prospectus
Comment 1: Page 9 Base Contract Expenses – Please delete the management fees and other expenses line items per Form N-4 instructions.
Response: Disclosure has been revised. Please see attached.
Comment 2: Page 26 – Regarding prior comment: “Comment 19: Fixed Annuity: Please delete this sentence “The SEC staff has not reviewed…”. Previous comment to delete was only referring to the first sentence. Suggest restoring the second sentence.
Response: Disclosure has been revised. Please see attached.
Comment 3: Bar Chart Attachment – Under the inception date column – Please confirm that 12/31/21 is the correct inception date.
Response: Disclosure has been revised. Please see attached.
II. Transamerica Variable Funds/ Transamerica Asset Allocation Variable Funds Statement of Additional Information
Comment 4: Page 11 regarding the N-3 Investment policies. It appears that the language is a duplicate. If duplicative please remove.
Home Office:
Harrison, NY
Administrative Office:
6400 C Street SW
Cedar Rapids, IA 52499
Response: Duplicate disclosures were deleted. Please see attached.
If you have any questions regarding these responses, please contact Brian Stallworth at 720-488-7884 or brian.stallworth@transamerica.com. I appreciate your assistance with this filing.
Sincerely,
/s/ Brian Stallworth
Show Raw Text
CORRESP 1 filename1.htm Transamerica Asset Allocation Variable Funds Home Office: Harrison, NY Administrative Office: 6400 C Street SW Cedar Rapids, IA 52499 April 20, 2022 [VIA EDGAR] Mr. Christopher Bellacicco, Esq. U.S. Securities and Exchange Commission 100 F Street NE Washington, DC 20549-0506 Re: Transamerica Financial Life Insurance Company Transamerica Variable Funds: Form N-4 Registration Statements (File No. 33-73734) Transamerica Asset Allocation Variable Funds: Form N-3 Registration Statements (File No. 333-08543) Mr. Bellacicco: This letter responds to comments that you provided via phone call on April 19, 2022, with respect to the above-referenced filings for the separate accounts of Transamerica Financial Life Insurance Company (“TFLIC”) relating to the Transamerica Variable Funds and Transamerica Asset Allocation Variable Funds variable annuities. For your convenience, I have restated those comments below, and followed each comment with our response. I. Transamerica Variable Funds/ Transamerica Asset Allocation Variable Funds Prospectus Comment 1: Page 9 Base Contract Expenses – Please delete the management fees and other expenses line items per Form N-4 instructions. Response: Disclosure has been revised. Please see attached. Comment 2: Page 26 – Regarding prior comment: “Comment 19: Fixed Annuity: Please delete this sentence “The SEC staff has not reviewed…”. Previous comment to delete was only referring to the first sentence. Suggest restoring the second sentence. Response: Disclosure has been revised. Please see attached. Comment 3: Bar Chart Attachment – Under the inception date column – Please confirm that 12/31/21 is the correct inception date. Response: Disclosure has been revised. Please see attached. II. Transamerica Variable Funds/ Transamerica Asset Allocation Variable Funds Statement of Additional Information Comment 4: Page 11 regarding the N-3 Investment policies. It appears that the language is a duplicate. If duplicative please remove. Home Office: Harrison, NY Administrative Office: 6400 C Street SW Cedar Rapids, IA 52499 Response: Duplicate disclosures were deleted. Please see attached. If you have any questions regarding these responses, please contact Brian Stallworth at 720-488-7884 or brian.stallworth@transamerica.com. I appreciate your assistance with this filing. Sincerely, /s/ Brian Stallworth Brian Stallworth Assistant General Counsel Annual Total Returns (calendar years ended December 31) Transamerica Asset Allocation - Intermediate/Long Horizon Subaccount Quarter Ended Return Best Quarter: 6/30/2020 6.67% Worst Quarter: 3/31/2020 -4.42% Average Annual Total Returns (periods ended December 31, 2021) 1 Year 5 Years 10 Years Inception Date Transamerica Asset Allocation - Intermediate/Long Horizon Subaccount Return before taxes 12.16 % 10.24 % 8.90 % 12/31/1996 Annual Total Returns (calendar years ended December 31) Transamerica Asset Allocation - Intermediate Horizon Subaccount Quarter Ended Return Best Quarter: 6/30/2020 15.07% Worst Quarter: 3/31/2020 -13.53% Average Annual Total Returns (periods ended December 31, 2021) 1 Year 5 Years 10 Years Inception Date Transamerica Asset Allocation - Intermediate Horizon Subaccount Return before taxes 9.11 % 8.37 % 7.16 % 12/31/1996 Annual Total Returns (calendar years ended December 31) Transamerica Asset Allocation - Short Horizon Subaccount Quarter Ended Return Best Quarter: 6/30/2020 19.10% Worst Quarter: 3/31/2020 -17.90% Average Annual Total Returns (periods ended December 31, 2021) 1 Year 5 Years 10 Years Inception Date Transamerica Asset Allocation - Short Horizon Subaccount Return before taxes 1.63 % 3.79 % 3.18 % 12/31/1996