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		ALIC N4 Correspondence 4-10 Combined Document

Sonny Oh, Esq.

April 13, 2020

Page 1

Allstate Life Insurance Company

P.O. Box 758566

Topeka, KS 66675-8566

April 13, 2020

VIA EDGAR

Sonny Oh, Esq.

Disclosure Review and Accounting Office

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC  20549

Re:

 Response to SEC Staff Comments on Post-Effective Amendment No. 19 to the

Registration Statement on Form N-4

SEC File Nos. 333-114560 and 811-09327

Allstate Financial Advisors Separate Account I (Registrant)

Allstate Life Insurance Company (Depositor)

Dear Mr. Oh:

On behalf of the above-referenced Registrant, below are responses to Staff comments received orally on Friday, April 3, 2020 on the registration statement noted above.  Included in this submission are a revised prospectus and Statement of Additional Information which are marked to show the changes described below. Also included is a revised Part C.

The Staff’s comments and our responses are as follows:

1.Comment:

Please disclose to the staff 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.

Response:

There are no agreements to disclose.

2. Comment:

Significant market events have occurred since this registration statement was filed as a result of the COVID-19 pandemic. Please consider whether the company’s disclosures, including market risk disclosures, should be revised based on how these events are affecting the markets of the

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April 13, 2020

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index that the company is using to calculate the company’s obligations under the contract. Further, given that the company’s obligations under the contract are subject to the financial

strength and claims-paying ability of the company, please consider whether this disclosure should be revised based on how these events could affect the company’s financial strength and claims-paying ability. If the company believes that no additional disclosure is warranted, please explain supplementally why not

Response:

We have added a fourth paragraph in the “More Information” section on page 85 to address this comment.

3.Comment:

Cover

Clearly disclose the registrant on the cover page.

Response:

The Registrant has been added to the cover page.

4. Comment:

Disclose that prospectus discloses all material features of the contracts, including all material state variations

Response:

This has been added to the cover page.

5. Comment:

Cover and SAI front page: Change to “The contracts are no longer being offered for sale as of X date…” (X date being when sales ceased)

Response:

We have changed the language to state the date the contracts were no longer offered for sale.

6. Comment:

Must list not just the fund/trust name but also the series and fund names

Response:

We have amended the list to correctly identify the trusts and funds.

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April 13, 2020

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7.Comment:

Bottom of page 1:  Credit enhancement: may be circumstances in which a contract owner could be worse off for having the credit enhancement and then identify the circumstances or give an example.

Response:

The language has been edited to adhere to the comment.

8. Comment:

Page 2:  Important Information; 1st 2 paragraphs: make sure to provide all required disclosure

Response:

We have reviewed and believe that all required disclosure is present.

9. Comment:

Definitions:

a.Fixed Account Options: for rates we ‘guarantee’ – disclose guaranteed minimum rate for those accounts.

b.“For more information concerning MVA…” Does the fixed account option include the MVA? Standard fixed account option

c.“Investment Alternatives” see first page – clarify the definition of investment alternatives, also includes the fixed account options

d.“SureIncome Plus Option fee” – at end of definition should be “sureincome Plus option”

e.“Tax qualified contract” – clarify – (TSA or IRA) should review annuity features for other additional benefits for holding an annuity within a qualified plan, other than tax deferral, since QP’s already offer tax deferral.

Response:

We have amended the definitions as requested.

10. Comment:

Page 5 - Footnote – four should be ‘three’ contracts

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April 13, 2020

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Response:

This has been corrected.

11. Comment:

Page 9 bottom: TrueBalance AAP: note that it is no longer offered

Response:

We have deleted the reference to the TrueBalance AAP.

12. Comment:

Page 11: Expense table: 1st paragraph: should be better aligned to what is in the form.

Response:

We have amended the paragraph to align with what is shown in that section.

13.Comment:

Top of page 12 – Only show max applicable fee in the table (ie: year zero) and footnote years 1 through 8

Variable annual expenses: max fee in footnote of 0.35% should be put in table (can add ‘maximum’ to the column name) then footnote the 0.19% as current applied rate

Response:

We have made both changes to show the maximum fees in the primary tables and noted the rest below.

14.Comment:

Page 15: Second and third rows of the tables can be combined since they are the same amounts, rename row as to include both circumstances

Response:

We have combined the second and third rows of the tables and renamed the rows to reflect the data shown.

15. Comment:

Page 20: Trial exam period: update: jurisdictions / states that require return of purchase payments, disclose that, and that the investor may have the right to recover the greater of purchase payments or guaranteed settlement value.

Response:

Amended the first paragraph under the Trial Examination Period section to reflect this.

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April 13, 2020

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16. Comment: AAPlus Contracts: confirm relief under sections 2a32 and 27i2A of reporting act and rule 22C-1 as to recapture of credit enhancement – confirmation that the registrant submits that the contracts being reviewed and the original regulatory relief relates to contracts that are substantially similar in all material respects to contracts for which any regulatory relief was granted.

Response:

We hereby submit that the contracts issued pursuant to the prospectus being reviewed are substantially similar in all material respects to contracts for which regulatory relief was granted under Sections 2a32 and 27i2A of the Investment Company Act and Rule 22c-1 thereunder, as to the recapture of the credit enhancement.

17. Comment:

Page 55: “The fixed account supports….” Clarify that the fixed account is part of the general account, and that insurance and annuity obligations are supported by the company’s general account; guaranteed benefits supported by company’s general account and in turn is subject to the company’s claims paying ability; therefore, contract owners should look to the financial stability of the company for its claims paying ability.

Response:

We have added in the additional information requested.

18. Comment:

Page 62: M&E: paragraph after that; 2nd sentence: the M&E expenses also…. Disclose that the company expects to make a profit from credit enhancement charges.

Response:

Added that the M&E charges will compensate us.

19. Comment:

Page 65: Free withdrawal amount: 1st paragraph: explain how the credit enhancement is treated with respect to calculating the withdrawal charges

Response:

We added in additional information regarding the credit enhancement.

20. Comment

Page. 71: “You may also elect…” paragraph: explain how the frequency and duration affect the level of annuity payments (lower / higher…)

Response:

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We added information that the payments may be higher or lower depending on the frequency and duration of the payments.

21. Comment:

Page 102: ERISA / Spousal consent: consider whether these sections apply (should be included) in the Custom Annuity S-1 and MVAs

Response:

We have forwarded this comment to the S-1 reviewers to consider.

22. Comment:

SAI – p. 4 and 5: Experts and financial statements and Part C 24A (financial statements) – revise each to reflect the appropriate financial statements of the depositor and registrant pursuant to Item 23

Response:

Revised to include the separate account financials.

23. Comment:

Powers of Attorney:

a.

 Is Bohaty’s missing?

b.  POA language: references 333-121693 – should this be deleted? Should it be a different number?

Response:

a)

 Bohaty is no longer with the Company and has been removed.

b)

 The POAs have been revised to properly identify the correct filing numbers.

If you have any questions, please call me at (402) 304-7695.

Very truly yours,

/s/ Jan Fischer-Wade

________________________

Jan Fischer-Wade

Senior Attorney

6

 Supplement dated May 1, 2020, to the

 Prospectus for your Variable Annuity

 Issued by

 ALLSTATE LIFE INSURANCE COMPANY

 This Supplement should be read in conjunction with the current Prospectus for your Annuity and should be retained for future reference. This Supplement is intended to update certain information in the Prospectus for the variable annuity you own and is not intended to be a prospectus or offer for any other variable annuity that you do not own. Defined terms used herein and not otherwise defined herein shall have the meanings given to them in the Prospectuses and Statements of Additional Information. If you have any questions, please contact your financial professional or our Variable Annuities Service Center at (800) 457-7617. Our representatives are available to assist you Monday through Friday between 7:30 a.m. and 5:00 p.m. Central time.

 On March 27, 2020 (Date of Enactment), Congress passed and President Trump signed the Coronavirus Aid, Relief and Economic Security (CARES) Act. This law includes provisions that impact Individual Retirement Annuities (IRAs), Roth IRAs and employer sponsored qualified retirement plans.

 Waiver of Required Minimum Distributions (RMDs) for 2020

 The requirement to take minimum distributions from defined contribution plans and IRAs is waived for 2020.  The waiver would apply to any RMD due from such an arrangement in 2020, even RMDs with respect to the 2019 tax year that are due in 2020.  For example, if an IRA owner turned age 70½ in 2019, they owe an RMD for the 2019 tax year but can wait until 4/1/20 to take it.  If they did not take that first RMD in 2019, the bill waives it, along with the requirement to take their second RMD (for the 2020 tax year) by the end of 2020.  The relief applies both to lifetime and post-death RMDs.  In that regard, if the post-death 5-year rule applies, the 5-year period is determined without regard to calendar year 2020 and thus, the 5 year rule is extended by one year.  It is unclear whether this treatment applies for the 10-year period imposed by the SECURE Act.  Although also unclear, the 1-year election rule for life expectancy payments by an eligible beneficiary may be extended based on the position the IRS took in Notice 2009-82.

 Withdrawals from Employer Plans and IRAs, including Roth IRAs

 Relief is provided for “coronavirus-related distributions” from qualified plans and IRAs. The relief applies to such distributions made at any time during the 2020 calendar year, as follows:

 •

  Permits such distributions to be treated as in-service distributions, even if such amounts are not otherwise distributable from the plan under sections 401(k), 403(b), or 457, as applicable;

 •

  Provides an exception to the 10% early distribution penalty under Code section 72(t) (but not for the similar penalty tax under Code section 72(q) that applies to non-qualified annuities);

 •

  Exempts such distributions from the 402(f) notice requirements and mandatory 20% withholding applicable to eligible rollover distributions, as applicable;

 •

  Permits the individual to include income attributable to such distributions ratably over the three-year period beginning with the year the distribution would otherwise be taxable (this spreading would apply unless the taxpayer elects out); and

 •

  Permits recontribution of such distribution to a plan or IRA within three years, in which case the recontribution is generally treated as a direct trustee-to-trustee transfer within 60 days of the distribution.

 The distribution must come from an “eligible retirement plan” within the meaning of Code section 402(c)(8)(B),  i.e. , an IRA, 401(a) plan, 403(a) plan, 403(b) plan, or governmental 457(b) plan. The relief would be limited to aggregate distributions of $100,000. See below for a description of who is eligible for the relief.

 Plan Loans

 The following relief is provided with respect to plan loans (if available under a contract) taken by any “qualified individual” who is affected by the coronavirus:

 •

  For loans made during the 180-day period beginning on the date of enactment, the maximum loan amount would be increased from $50,000 or 50% of the vested account balance to $100,000 or 100% of the vested account balance.  Note that Department of Labor regulations require that plan loans be secured by no more than half of the account balance.  It is not clear whether this is an impediment to increasing the loan limit to 100% of the account balance.  We understand that DOL is aware of this issue.

 •

  The due date for any repayment on a loan that otherwise is due between the date of enactment and December 31, 2020, would be delayed for one year.  This also would extend the maximum loan period (normally five years).

 Based on prior IRS guidance involving similar relief for natural disasters, all of the changes would be optional for plans See below for a description of who is eligible for the plan loan relief.

ASADVISOR

 Eligible Individuals for Withdrawal and Loan Relief

 The administrator of an eligible retirement plan may rely on an employee’s certification that the employee satisfies the conditions for eligibility.  The eligibility criteria for the relief remain the same, meaning the individual must fall within one of the following categories:

 •

  The individual is diagnosed with the virus SARS-CoV-2 or with coronavirus disease 2019 (COVID-19) by a test approved by the Centers for Disease Control and Prevention;

 •

  The individual’s spouse or dependent is diagnosed with such virus or disease; or

 •

  The individual experiences adverse financial consequences as a result of being quarantined, being furloughed or laid off or having work hours reduced due to such virus or disease, being unable to work due to lack of child care due to such virus or disease, closing or reducing hours of a business owned or operated by the individual due to such virus or disease, or other factors as determined by the Secretary of the Treasury.

 IRS Guidance

 Extension of IRA Contribution Deadline

 The deadline for making an IRA or Roth IRA contribution has been extended until July 15, 2020, the extended deadline for filing an individual’s 2019 tax return.

ASADVISOR

The Allstate Advisor Variable Annuities

(Advisor, Advisor Plus, Advisor Preferred)

ALLSTATE FINANCIAL ADVISORS SEPARATE ACCOUNT I

Allstate Life Insurance Company

Street Address: 5801 SW 6th Ave., Topeka KS, 66606-0001

Mailing Address: P.O. Box 758566, Topeka, KS 66675-8566

Telephone Number: 1-800-457-7617

Fax Number: 1-785-228-4584

 Prospectus dated May 1, 2020

Allstate Life Insurance Company (“Allstate Life”)  offered  the following individual and group flexible premium deferred variable annuity contracts (each, a “Contract”):

•

 Allstate Advisor

•

 Allstate Advisor Plus

•

 Allstate Advisor Preferred

 The Contracts are no longer offered for sale as of January 14, 2008. If you have already purchased a Contract you may continue to add to it. Each additional payment must be at l