Correspondence 0001104659-24-044220 from SEPARATE ACCOUNT A OF PACIFIC LIFE & ANNUITY CO (CIK 0001074486)
SEPARATE ACCOUNT A OF PACIFIC LIFE & ANNUITY CO (CIK 0001074486)
Date: April 5, 2024 · CIK: 0001074486 · Accession: 0001104659-24-044220
AI Filing Summary & Sentiment
File numbers found in text: 333-185329, 811-09203
Letter
ALISON RYAN
Assistant Vice President &
Managing Assistant General Counsel II
OGC Retail Legal & Compliance
(949) 219-3268 Telephone
Alison.Ryan@PacificLife.com
April 5, 2024
Mr. Michael Rosenberg
Attorney-Adviser
Office of Insurance Products
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-0506
RE: Post-Effective Amendment No. 27 to the Registration Statement for Pacific Odyssey NY (2013), (File No. 333-185329), funded through Separate Account A (File Number 811-09203) of Pacific Life & Annuity Company:
On behalf of Pacific Life & Annuity Company (“Pacific Life”) and Separate Account A (“Separate Account”) of Pacific Life, set forth below are responses to Staff comments received March 27, 2024, in connection with the above-referenced Post-Effective Amendments, on Form N-4, filed February 15, 2024 in a filing made pursuant to Rule 485(a) of the Investment Company Act of 1940 (“1940 Act”).
Staff Comments
1. Staff Comment: FEE TABLES, Annual Contract Expenses – Please add disclosure to the fee table indicating that the Base Contract Expense was 0.40% if your contract was issued before December 1, 2016. This should appear in the fee table, not just in a footnote.
Response: Revisions have been made to address the Staff’s comment.
I believe that the foregoing is responsive to the Staff’s comments. All disclosure changes included in this response will be made via a post-effective amendment to the registration statement referenced above pursuant to Rule 485(b) of the 1940 Act. Pacific Life intends to file such post-effective amendment on April 18, 2024, and would appreciate any additional comments from the Staff no later than April 12, 2024.
If you have any questions, please call me at (949) 219-3268.
Sincerely,
/s/ Alison Ryan
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CORRESP 1 filename1.htm ALISON RYAN Assistant Vice President & Managing Assistant General Counsel II OGC Retail Legal & Compliance (949) 219-3268 Telephone Alison.Ryan@PacificLife.com April 5, 2024 Mr. Michael Rosenberg Attorney-Adviser Office of Insurance Products Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-0506 RE: Post-Effective Amendment No. 27 to the Registration Statement for Pacific Odyssey NY (2013), (File No. 333-185329), funded through Separate Account A (File Number 811-09203) of Pacific Life & Annuity Company: On behalf of Pacific Life & Annuity Company (“Pacific Life”) and Separate Account A (“Separate Account”) of Pacific Life, set forth below are responses to Staff comments received March 27, 2024, in connection with the above-referenced Post-Effective Amendments, on Form N-4, filed February 15, 2024 in a filing made pursuant to Rule 485(a) of the Investment Company Act of 1940 (“1940 Act”). Staff Comments 1. Staff Comment: FEE TABLES, Annual Contract Expenses – Please add disclosure to the fee table indicating that the Base Contract Expense was 0.40% if your contract was issued before December 1, 2016. This should appear in the fee table, not just in a footnote. Response: Revisions have been made to address the Staff’s comment. I believe that the foregoing is responsive to the Staff’s comments. All disclosure changes included in this response will be made via a post-effective amendment to the registration statement referenced above pursuant to Rule 485(b) of the 1940 Act. Pacific Life intends to file such post-effective amendment on April 18, 2024, and would appreciate any additional comments from the Staff no later than April 12, 2024. If you have any questions, please call me at (949) 219-3268. Sincerely, /s/ Alison Ryan Alison Ryan