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[ALLSTATE LOGO]

April 16, 2021

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. 21 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 Monday, April 12, 2021 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: Page 1 – For the credit enhancement recapture, check to make sure this sentence is accurate with respect to death, annuitization and surrender:

In certain circumstances (such as death, annuitization, or surrendering your contract within a few years of purchasing it, or upon cancellation during the Trial Examination Period) we may recapture the Credit Enhancement.

Response: We have verified that the credit enhancement is not recaptured at death, annuitization or surrender. In addition, since this product is no longer sold, we have deleted this sentence. We have also deleted this in the other areas it was included in previously. (Key Information Table second paragraph of “Charges for Early Withdrawals” row; Overview of the Contract section “Purpose” row, end of third paragraph; and the Principal Risks narrative section discussing the Credit Enhancement)

2)Comment: Table of Contents: Move “Benefits Available Under the Contract” down so that is chronologically in order.

Response: This has been changed

Sonny Oh, Esq.

April 16, 2021

Page 2

3)Comment: Key Information Table: Ongoing Fees and Expenses section: the basis for the fee calculation for the Investment Options should be “… as a percentage of portfolio average daily net assets” not ‘separate account assets”.

Response: This has been changed.

4)Comment: Page 12: Principal Risks section, move the credit enhancement disclosure from “Not a Short-Term Investment” to a sub-section of its own.

Response: We have created a new sub-section for this disclosure entitled “Credit Enhancement”.

5)Comment: Benefits Table / Optional Benefits: Need examples of the following:

Spousal Protection Benefit (Co-Annuitant) Option

Spousal Protection Benefit (Co-Annuitant) Option for Custodial IRAs

Return of Premium Death Benefit

SureIncome Return of Premium Death Benefit

MAV Death Benefit Option

Response:

Spousal Protection Benefit (Co-Annuitant) Option and Spousal Protection Benefit (Co-Annuitant Option for Custodial IRAs: The Spousal Protection Benefits are continuation benefits which allows the co-annuitant to take over as annuitant if the annuitant dies during the accumulation phase.  For each, once payments begin, the benefit terminates, and no change of annuitant is allowed.  There are no numerical mechanics to demonstrate how the benefit operates but there is already ample textual description describing how the benefit operates.

Return of Premium Death Benefit: Response: Example is in Appendix G, but we fixed wording to make this clearer. The existing example covers the sole moving part of the ROP death benefits.  The death benefit is the premium, adjusted for withdrawals, which this example illustrates.

SureIncome Return of Premium Death Benefit: Response: Example is in Appendix G, but we added some wording to make this clearer.

MAV Death Benefit Option: Example is in Appendix G.

6)Comment: Benefits Table / Optional Benefits: Return of Premium (ROP) Death Benefit – Is there a standard ROP in addition to the one offered with the SureIncome Plus and for Life Withdrawal Benefit Options? If so, include a separate row for that.

2

Sonny Oh, Esq.

April 16, 2021

Page 3

Response: Yes, there are two ROPs – one standard and one that is included with the SureIncome Withdrawal Benefit Options. We have added another row so as to include both ROP benefits in the chart now – one standard and one that is called “SureIncome Return of Premium (“ROP”) Death Benefit.

7)Comment: Verify that the Tax section been updated

Response: Yes, the Tax section has been updated

8)Comment: Appendix B, page B-9, for the Income Protection Benefit chart, include footnote (1) in the title of the third column as well.

Response: We have made this change.

9)Comment: In the SAI, add in the section from the prospectus about the Net Investment Factor above the Calculation of Annuity Unit Values.

Response: We have added in that section.

10)Comment: In the Calculation of Annuity Unit Values, in the last paragraph, “accumulation” should be “annuity”

Response: We have made the change

11)Comment: Financial Statement section: this needs to be updated to reflect what is actually being done with the financials, since a 10-k is no longer filed.

Response: We have updated this section to delete the last paragraph that is N/A now.

12)Comment: Part C: Make sure to include (o) and state “Not applicable”

Response: This correction has been made

13)Comment: Part C: Make sure “filed herewith” documents are hyperlinked

Response: The final 485B filing will include all hyperlinks for those documents.

14)Comment: Part C: May omit Item 32 if this is in the N-CEN report

Response: We prefer to keep item 32 as it is.

3

Sonny Oh, Esq.

April 16, 2021

Page 4

15)Comment: Part C: Table of Exhibits: don’t include an item in the list if it is not included in the file.

Response: We have reviewed the items and believe all are required per the rules.

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

Very truly yours,

/s/ Jan Fischer-Wade

Jan Fischer-Wade

Senior Counsel

4

The Allstate Advisor Variable Annuities

(Advisor, Advisor Plus, Advisor Preferred)

Registrant: ALLSTATE FINANCIAL ADVISORS SEPARATE ACCOUNT I

Issued by: Allstate Life Insurance Company (“Allstate Life”)

Allstate Life Insurance Company

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

Mailing Address: P.O. Box 758543, Topeka, KS 66675-8566

Telephone Number: 1-800-457-7617

Fax: 1-785-228-4584

Prospectus dated April 30, 2021

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

•  Allstate Advisor

•  Allstate Advisor Plus

•  Allstate Advisor Preferred with 5-Year Withdrawal Charge Option

•  Allstate Advisor Preferred with 3-Year Withdrawal Charge Option

•  Allstate Advisor Preferred with No Withdrawal Charge Option

The Contracts are no longer offered for new sales effective January 14, 2008. If you have already purchased a Contract you may continue to make purchase payments according to the Contract. Each additional purchase payment must be at least $1,000.

There are various Investment Alternatives available to you under your Contract, including the Market Value Adjusted Fixed Account Option (the “Market Value Adjusted Fixed Account Option” or “MVA Account Option”). If you are interested in allocating Contract Value to the MVA Account Option, please refer to the separate prospectus for the MVA Account Option (the “MVA Account prospectus”). If you did not receive an MVA Account prospectus and wish to obtain one, please write or call us at the address or telephone number above.

For the Allstate Advisor Plus Contracts with the Credit Enhancement,  the expenses  may be higher than for contracts without a Credit Enhancement,  the amount of the Credit Enhancement may be more than offset by the additional fees and charges associated with the Allstate Advisor Plus Contract, and the withdrawal charge period is longer.

Additional information about certain investment products, including variable annuities, has been prepared by the Securities and Exchange Commission’s staff and is available at Investor.gov.

IMPORTANT INFORMATION

As of January 1, 2021, as permitted by regulations adopted by the Securities and Exchange Commission, paper copies of the annual and semi-annual shareholder reports for portfolios available under your contract are no longer sent by mail, unless you specifically request paper copies of the reports from us.  Instead, the reports are available online at www.AccessAllstate.com, and you will be notified by mail each time a report is posted and provided with a website link to access the report.

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.

You may elect to receive all future shareholder reports in paper free of charge by calling 1-800-457-7617.  Your election to receive reports in paper will apply to all portfolios available under your contract.

IMPORTANT NOTICES The SEC has not approved or disapproved the securities described in this prospectus, nor has it passed on the accuracy or the adequacy of this prospectus. Anyone who tells you otherwise is committing a federal crime.

The Contracts may be distributed through broker-dealers that have relationships with banks or other financial institutions or by employees of such banks. However, the Contracts are not deposits in, or obligations of, or guaranteed or endorsed by, such institutions or any federal regulatory agency. Investment in the Contracts involves investment risks, including possible loss of principal.

The Contracts are not FDIC insured.

ASADVISOR

Table of Contents

 Page

Overview

Glossary of Terms

 1

Important Information You Should Consider About the Contract

 4

Expense Table

 8

Principal Risks of Investing in the Contract

 11

Contract Features

The Contract

 12

Purchases

 15

Contract Value

 17

Investment Alternatives

 36

The Variable Sub-Accounts

 36

The Fixed Account Options

 39

Transfers

 42

Expenses

 45

Access To Your Money

 52

Benefits Available Under the Contract

 54

Income Payments

 57

Death Benefits

 64

More Information

Allstate Life

 73

The Variable Account

 73

The Portfolios

 73

Principal Underwriter

 74

Non-Qualified Annuities Held Within a Qualified Plan

 76

Legal Matters

 76

Taxes

 77

Appendix A – Investment Portfolios Available Under the Contract

 A-1

Appendix B – Variable Sub-Accounts Available Under the Benefits Offered Under the Contracts

 B-1

Appendix C – Allstate Advisor Contract Comparison Chart

 C-1

Appendix D- Contract Feature Calculation Examples D-1

Appendix E – Example of Calculation of Income Protection Benefit

 E-1

Appendix F - Calculation of Retirement Income Guarantee 1 and 2 F-1

Appendix G – Withdrawal Adjustment Example - Death Benefits

 G-1

Appendix H – Calculation of Earnings Protection Death Benefit

 H-1

Appendix I – Withdrawal Adjustment Example - TrueReturn Accumulation Benefit

 I-1

Appendix J – SureIncome Withdrawal Benefit Option Calculation Examples

 J-1

Appendix K – SureIncome Plus Withdrawal Benefit Option Calculation Examples

 K-1

Appendix L – SureIncome For Life Withdrawal Benefit Option Calculation Examples

 L-1

Appendix M - Enhanced Beneficiary Protection (Annual Increase) Option Calculation Examples

 M-1

Appendix N - State Variation Chart

 N-1

(i)

Allstate Advisor Glossary

We set forth here definitions of some key terms used throughout this prospectus. In addition to the definitions here, we also define certain terms in the sections of the prospectus that use such terms.

Accumulation Phase- The period that begins on the date we issue your Contract (“Issue Date”) and continues until the Payout Start Date, which is the date we apply your money to provide income payments.

Accumulation Unit- A unit of measurement used to measure the value of your investment in the Variable Sub-Accounts during the Accumulation Phase. To determine the number of Accumulation Units of each Variable Sub-account to allocate to your Contract, we divide (i) the amount of the purchase payment or transfer you have allocated to a Variable Sub-account by (ii) the Accumulation Unit Value of that Variable Sub-account next computed after we receive your payment or transfer.

Accumulation Unit Value- Each Variable Sub-Account has a separate value for its Accumulation Units (this is analogous to, but not the same as, the share price of a mutual fund).

Allstate Life (“we”)-  The issuer of the Allstate Advisor, Allstate Advisor Plus, and Allstate Advisor Preferred Variable Annuities, each an individual and group flexible premium deferred variable annuity contract (“Contract”).

Annuitant- The individual whose age determines the latest Payout Start Date and whose life determines the amount and duration of income payments (other than under Income Plan 3). The maximum age of the Annuitant on the date we receive the completed application for each Contract is 90.

Automatic Additions Program- A programs that permits subsequent purchase payments of $50 or more per month by automatically transferring money from your bank account. The Automatic Additions Program is not available for making purchase payments into the Dollar Cost Averaging Fixed Account Option.

Automatic Portfolio Rebalancing Program- A program that provides for the automatic rebalancing of the Contract Value in each Variable Sub-Account and return it to the desired percentage allocations after the performance of each Sub-Account causes a shift in the percentage you allocated to each Sub-Account.

Beneficiary(ies)- The person(s) or entity(ies), who will receive the benefits that the Contract provides when the last surviving Contract Owner dies, or, if the Contract Owner is a non-living person, an Annuitant dies. You may name one or more Primary and Contingent Beneficiaries when you apply for a Contract.

•Primary Beneficiary- the person who may, in accordance with the terms of the Contract, elect to receive the death settlement (“Death Proceeds”) or become the new Contract Owner pursuant to the Contract if the sole surviving Contract Owner dies before the Payout Start Date. If the sole surviving Contract Owner dies after the Payout Start Date, the Beneficiary will receive any guaranteed income payments scheduled to continue.

•Contingent Beneficiary- the person selected by the Contract Owner who will exercise the rights of the Primary Beneficiary if all named Primary Beneficiaries die before the death of the sole surviving Contract Owner.

Co-Annuitant- An individual who will be considered to be an Annuitant during the Accumulation Phase, except the Co-Annuitant will not be considered an Annuitant for purposes of determining the Payout Start Date. In addition, the “Death of Annuitant” provision of your Contract does not apply upon the death of the Co-Annuitant.

Code- The Internal Revenue Code of 1986, as amended.

Contract- Allstate Advisor, Allstate Advisor Plus, Allstate Advisor Preferred,  are each an individual and group flexible premium deferred variable annuity contract between you, the Contract owner, and Allstate Life, a life insurance company.  In certain states the Contract was available only as a group Contract. In these states, we issued you a certificate that represents your ownership and that summarizes the provisions of the group Contract. References to "Contract" in this prospectus include certificates unless the context requires otherwise.

Contract Anniversary- Each twelve-month period from the date of your contract’s issue date.

Contract Owner (“you”)- The person(s) having the privileges of ownership defined in the Contract.

Contract Value- During the Accumulat