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		N-4/A Correspondence 4.15.2020 Combined Document

[ALLSTATE LOGO]

April 16, 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 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

Sonny Oh, Esq.

April 16, 2020

Page 2

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.

UPDATED COMMENT & RESPONSE:

Comment: Need to add the Registrant to the SAI

Response: We have added the Registrant to the SAI on first 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.

UPDATED COMMENT & RESPONSE:

Comment: Need to list all of the investment alternatives

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Sonny Oh, Esq.

April 16, 2020

Page 3

Response: We have added the entire listing of the portfolios, and in doing so, made some minor changes to the language regarding the funds and portfolios to coincide with the changed list.

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.

UPDATED COMMENT & RESPONSE:

Comment: Need to add additional disclosure

Response: We have added the required disclosure that was missing:

“If you already elected to receive shareholder reports electronically, you will not be affected by this change and you need not take any action. You may elect to receive shareholder reports and other communications electronically by calling 1-800-457-7617.”

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.

UPDATED COMMENT & RESPONSE:

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Sonny Oh, Esq.

April 16, 2020

Page 4

Comment a: Is the minimum guaranteed rate for the MVA fixed account option also 3%?

Response a: No, there is no minimum guaranteed rate for it. We have updated the language accordingly to say “The guaranteed rate for the Dollar Cost Averaging Fixed Account Option and the Standard Fixed Account Option is 3%.  There is no guaranteed rate for the Market Value Adjusted Fixed Account Option.”

UPDATED COMMENT & RESPONSE:

Comment e: Changes did not show up for this definition

Response: We have added in “annuities” after “tax sheltered” in the first line and added “other” after “you should review the” in the second line.

UPDATED COMMENT & RESPONSE:

Comment - new: Need to delete “in most states as” in the Right to Cancel definition

Response: We have deleted that language

10. Comment:

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

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.

UPDATED COMMENT & RESPONSE:

Comment: Need to re-work the information ahead of the expense tables to clarify what is in the tables shown.

Response: We have changed the language to identify what is shown in the expense tables,  and moved the contract maintenance charge and transfer fee to a new table to show periodic fees that may be imposed.

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

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Sonny Oh, Esq.

April 16, 2020

Page 5

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 comment a.

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.

UPDATED COMMENT & RESPONSE:

Comment: Need to correctly cite the provisions

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 2(a)(32), 22(c) and 27(i)(2)(A) 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.

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Sonny Oh, Esq.

April 16, 2020

Page 6

Response:

We have added in the additional information requested.

UPDATED COMMENT & RESPONSE:

Comment: Need to re-work the additions as discussed (move ‘guaranteed benefits’; change ‘stability’ to ‘strength’)

Response: We have edited the paragraph to conform to the comments discussed.

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.

UPDATED COMMENT & RESPONSE:

Comment: Need to add language specific to expecting to make a profit from the credit enhancement charges.

Response: We added the following to the beginning of the second to last sentence in the paragraph below the M&E charge table: “The Company anticipates that it will make a profit from the Credit Enhancement, but” [if the charges under the Contract are not sufficient, then we will bear the loss.]

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.

UPDATED COMMENT & RESPONSE:

Comment: Need to add language in the Withdrawal Charge section about how the credit enhancement is taken into account when assessing withdrawal charges.

Response: We added a sentence in the Withdrawal Charge section as requested: “Any applied credit enhancements are also subject to withdrawal charges.”

20. Comment

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

Response:

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

UPDATED COMMENT & RESPONSE:

Comment: Need to be specific about the effects of the duration and frequency of the payments.

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Sonny Oh, Esq.

April 16, 2020

Page 7

Response: We added the following sentence to the paragraph: “For example, the shorter the duration of payments, the higher they will be; and the higher the frequency of payments, the lower they will be.”

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.

UPDATED COMMENT & RESPONSE:

Comment: Need to list out the specific financial statements.

Response: We have added the lists for both ALIC and the Separate Account

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.

UPDATED COMMENT & RESPONSE:

Comment: Item 26 in Part C: Need to specify where in the 10-K this is found.

Response: We have added “Exhibit 21” as to where to find the information.

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

Very truly yours,

/s/ Jan Fischer-Wade

Jan Fischer-Wade

Senior Attorney

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Filed with the Securities and Exchange Commission on April 16, 2020

REGISTRATION NO. 333-114560

INVESTMENT COMPANY ACT NO. 811-09327

===============================================================================================

SECURITIES AND EXCHANGE COMMISSION

WASHINGTON, D.C. 20549

-----------------

FORM N-4

-----------------

REGISTRATION STATEMENT

UNDER

THE SECURITIES ACT OF 1933

POST-EFFECTIVE AMENDMENT NO. 20

and

REGISTRATION STATEMENT

UNDER

THE INVESTMENT COMPANY ACT OF 1940

AMENDMENT NO. 176

-----------------

ALLSTATE FINANCIAL ADVISORS SEPARATE ACCOUNT I

(Exact Name of Registrant)

ALLSTATE LIFE INSURANCE COMPANY

(Name of Depositor)

3075 SANDERS ROAD

NORTHBROOK, ILLINOIS 60062-7127

(847) 402-5000

 (Address and telephone number of Depositor's principal executive offices)

-----------------

ANGELA FONTANA

DIRECTOR, VICE PRESIDENT, SECRETARY & GENERAL COUNSEL

ALLSTATE LIFE INSURANCE COMPANY

3075 SANDERS ROAD

NORTHBROOK, ILLINOIS 60062-7127

(Name and address of agent for service)

COPIES TO:

JAN FISCHER-WADE, ESQ.

SENIOR ATTORNEY

ALLSTATE LIFE INSURANCE COMPANY

2940 S. 84th Street

Lincoln, NE 68506-4142

Approximate Date of Proposed Sale to the Public: Continuous

-----------------

It is proposed that this filing become effective: (check appropriate space)

[  ] immediately upon filing pursuant to paragraph (b) of Rule 485

[X] on May 1, 2020 pursuant to paragraph (b) of Rule 485

[  ] 60 days after filing pursuant to paragraph (a)(i) of Rule 485

[  ] on __________ pursuant to paragraph (a)(i) of Rule 485

If appropriate, check the following box:

[  ] This post-effective amendment designates a new effective date for a previously filed post-effective amendment.

TITLE OF SECURITIES BEING REGISTERED:

Units of interest in Separate Accounts under variable annuity contracts.

===============================================================================================

 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.

 Note: You should consult with us and your tax advisor as provisions enacted in response to the COVID-19 outbreak continue to evolve, as additional information is received and communicated by the IRS and the Department of Lab or.

 On March 27, 2020