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SEC Company Response from AMERICAN ENTERPRISE VARIABLE LIFE ACCOUNT (CIK 0001092279) — Dec 13, 2004

AMERICAN ENTERPRISE VARIABLE LIFE ACCOUNT (CIK 0001092279)
Date: Dec. 13, 2004 · CIK: 0001092279 · Accession: 0000820027-04-001034

AI Filing Summary & Sentiment

File numbers found in text: 333-84121, 811-09515

Date
December 10, 2004
Author
/s/ Eric L. Marhoun
Form
CORRESP
Company
AMERICAN ENTERPRISE VARIABLE LIFE ACCOUNT (CIK 0001092279)

Letter

VIA EDGAR and FACSIMILE (Correspondence Filing) Mark Cowan Office of Insurance Products Division of Investment Management Securities and Exchange Commission 450 Fifth Street, N.W. (Mail Stop 5-6) Washington, D.C. 20549-1004 ATTN: Document Control - Edgar American Express Signature Variable Universal Life Insurance(R) Post-Effective Amendment No. 7 On From N-6 (File No. 333-84121) Investment Company Act No. 811-09515

RE: American Enterprise Variable Life Account ("Registrant")

Dear Mr. Cowan:

This letter is in response to Staff's oral comments sent via voicemail on or about December 10, 2004 for the Registrant and Post-Effective Amendments (collectively, the "Amendments") listed above. Staff had no comments except the requirement to make the following representation on behalf of the Registrant:

In connection with the Amendments, American Enterprise Life Insurance Company, (the "Company") on behalf of the Registrant, hereby acknowledges the following:

The disclosures in the filing are the responsibility of the Company and the Company is fully responsible for the adequacy or accuracy of the disclosures in this filing. The Company represents to the Commission that comments made by the Commission, or the staff acting pursuant to delegated authority, or changes to disclosure in response to staff comments in the filing reviewed by the staff, do not foreclosure the Commission from taking any action with respect to the filing, and the Company represents that it will not assert this action as a defense in any proceeding initiated by the Commission or any person, under the federal securities laws of the United States.

If you have any additional questions, please call Mary Ellyn Minenko at 612-671-3678 or Simone Pepper at 612-671-2847.

Sincerely,
/s/ Eric L. Marhoun
-----------------------
Eric L. Marhoun
General Counsel
American Enterprise Life Insurance Company

Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>ael-correp.txt
<DESCRIPTION>AMERICAN ENTERPRISE VARIABLE LIFE ACCOUNT
<TEXT>
December 10, 2004

VIA EDGAR and FACSIMILE (Correspondence Filing)

Mark Cowan
Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.  (Mail Stop 5-6)
Washington, D.C. 20549-1004

ATTN:          Document Control - Edgar

RE:            American Enterprise Variable Life Account ("Registrant")

               American Express Signature Variable Universal Life Insurance(R)
               Post-Effective Amendment No. 7
               On From N-6 (File No. 333-84121)
               Investment Company Act No. 811-09515

Dear Mr. Cowan:

This letter is in response to Staff's oral comments sent via voicemail on or
about December 10, 2004 for the Registrant and Post-Effective Amendments
(collectively, the "Amendments") listed above. Staff had no comments except the
requirement to make the following representation on behalf of the Registrant:

In connection with the Amendments, American Enterprise Life Insurance Company,
(the "Company") on behalf of the Registrant, hereby acknowledges the following:

         The disclosures in the filing are the responsibility of the Company and
         the Company is fully responsible for the adequacy or accuracy of the
         disclosures in this filing. The Company represents to the Commission
         that comments made by the Commission, or the staff acting pursuant to
         delegated authority, or changes to disclosure in response to staff
         comments in the filing reviewed by the staff, do not foreclosure the
         Commission from taking any action with respect to the filing, and the
         Company represents that it will not assert this action as a defense in
         any proceeding initiated by the Commission or any person, under the
         federal securities laws of the United States.

If you have any additional questions, please call Mary Ellyn Minenko at
612-671-3678 or Simone Pepper at 612-671-2847.

Sincerely,

/s/  Eric L. Marhoun
-----------------------
     Eric L. Marhoun
     General Counsel
     American Enterprise Life Insurance Company

Cc:      Mary Ellyn Minenko
         Simone Pepper

</TEXT>
</DOCUMENT>