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SEC Correspondence

 BY EDGAR

 June 16, 2020

Patrick F. Scott, Senior Counsel

 Division of Investment Management

Disclosure Review and Accounting Office

 U.S. Securities and Exchange Commission

 100 F Street NE

 Washington, D.C. 20549

Re:
 Thrivent Variable Annuity Account I (“Registrant”);

 Initial Registration Statement on Form N-4 (“Registration Statement”
or “filing”):

 Thrivent Retirement Choice Variable Annuity (“Contract” or “VA”);

 Issued by Thrivent Financial for Lutherans (“Company”);

 File No. 811-21111 / 333-237618

 Dear Mr. Scott:

 This correspondence provides
detailed responses to the letter you sent VIA EMAIL regarding the above referenced filing. The filing included two prospectuses. Please be advised Thrivent has decided to only offer one prospectus, the Thrivent Retirement Choice Variable Annuity.

 A. General:

Comment 1: Please clarify supplementally whether there are any
guarantees or support agreements with third parties to support any of the benefits or features under the contract or whether the Company will be solely responsible for any benefits or features associated with the Contract.

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 Response to Comment 1:

 The Registrant does not have any types of guarantees or support agreements with third parties to support
insurance benefits or features under the contract. The Registrant has entered into participation agreements with third parties to be able to offer certain investment options. Those participation agreements have been, or will be, filed as part of the
amended registration statement.

 Comment
2:    Please confirm that Prospectus has been or will be updated as necessary to reflect changes effected by the SECURE Act and the CARES Act.

Response to Comment 2:

Yes, the Prospectus will be updated to address the changes from the SECURE Act and the CARES Act that directly affect the product. The following
provisions have been added to the Federal Tax Status section.

 SECURE Act Notice. Effective January 1, 2020, pursuant to the Setting Every Community Up for Retirement Enhancement (“SECURE”) Act, the age at which you must begin taking
your required minimum distributions (“RMDs”) from your tax-qualified contract (IRA) has been raised to age 72 from 701⁄2. If you turned 701⁄2 in 2019, you are still required to use age
701⁄2 as the triggering age for RMDs.

 Also
effective on January 1, 2020, the ability for beneficiaries to “stretch” their RMDs over their life expectancy is no longer available for most beneficiaries. Instead, a
non-spouse beneficiary is now required to draw down the entire inherited interest within ten (10) years. The ten-year rule does not apply to any portion payable to
a surviving spouse, who may still “stretch” the post-death distributions for their life or a period not exceeding their life expectancy. Some additional exceptions to the ten-year rule may apply. You
should consult your tax advisor if any of these changes could impact your IRA contract.

 CARES Act
Notice. Effective March 27, 2020, the Coronavirus Aid, Relief, and Economic Security (“CARES”) Act made several retirement related changes that may impact you.

For 2020 only, the CARES Act permits corona-virus related distributions from tax-qualified
contracts and IRAs up to an aggregate amount of $100,000. This type of distribution is an exception to the 10% federal tax penalty. To qualify for the distribution, generally you, your spouse, or dependent must have

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been diagnosed with the virus, or you were impacted financially in certain ways because of the virus.

The tax associated with the distributions may be paid ratably over three years, beginning with the 2020 tax year. The CARES Act also allows you
to recontribute the amount you withdrew to an eligible retirement plan (to which you can make a rollover contribution) in one or more payments within three years. The CARES Act provides additional withdrawal and loan relief (subject to availability)
for tax-qualified contracts and IRAs in 2020 for eligible individuals. Please consult with your tax advisor if you have any questions on how these changes could impact you.

Comment 3:     The Prospectus states that
any guarantees provided for under the Contract or through the riders, along with amounts invested in the fixed account, are subject to the Company’s financial strength and claims-paying ability. Given the significant market events that have
occurred as a result of the COVID-19 pandemic, please consider whether the disclosure should be revised based on how these events could affect the Company’s financial strength and claims-paying ability,
including the ability to timely process claims. If the Company believes that no additional disclosure is warranted, please explain supplementally why not.

Response to Comment 3:

The Registrant’s claims related to COVID-19 have been negligible. Over the last several months,
Thrivent’s strength and claims-paying ability has not been impacted by the COVID-19 pandemic.

 To
address the comment, the Registrant has added the underlined sentence to the existing disclosure on the potential impacts of the COVID-19 pandemic in the “Risks” section of the prospectus found on
page 28.

 Health Crisis Risk. The global pandemic
outbreak of the novel coronavirus known as COVID-19 has resulted in substantial market volatility and global business disruption. The duration and full effects of the outbreak are uncertain and may result in
trading suspensions and market closures, limit liquidity and the ability of the Fund to process Contract Owner redemptions, and negatively impact Fund performance. The COVID-19 outbreak and
future pandemics could affect the global economy in ways that cannot be foreseen and may exacerbate other types of risks, negatively impacting the value of the Fund. These

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events have not affected Thrivent’s financial strength or claims-paying ability.

Comment 4:    The Contract appears to be
available through fee-based financial advisors but also imposes a surrender charge. Please supplementally explain in greater detail the purpose of the surrender charge.

Response to Comment 4:

The Contract will be offered as a standard, commission-based product. Unlike Thrivent’s AdvisorFlex Variable Annuity filed in 2017, this product
is a stand-alone variable annuity that is not sold as part of a managed account arrangement.

 The Contract provides for a Fixed Account with a
guaranteed minimum interest rate. The guaranteed minimum interest rate is required under state insurance laws. The surrender charge provision makes it possible for Thrivent to provide for this guaranteed minimum interest rate by reducing the
likelihood of a contract owner using this annuity solely as a short-term interest-bearing product. In addition, the surrender charge also helps with the expenses incurred for us to issue the contract.

Comment 5:    Please explain whether the
fees paid to the investment advisor are paid out of Accumulated Value. If so, clarify how these amounts are treated under the contract and for tax purposes (e.g.,
are they considered a withdrawal).

 Response to Comment 5:

 This product is a stand-alone commission-based annuity. It is not sold as part of a managed account
arrangement. Therefore, there are no investment advisor fees.

 Comment
6: Please confirm supplementally to the staff, that the Contract name associated with the Series/Class page on EDGAR is the same name as disclosed within the Contract prospectus, as filed.

Response to Comment 6:

The Registrant will be issuing only the Thrivent Retirement Choice Variable Annuity.

The Contract name associated with the Series/Class page on EDGAR will be reflected as follows:

C000220060 - Thrivent Retirement Choice Variable Annuity

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 B. Prospectus

1.
 Fee and Expense Table and Examples (pp. 7-10):

 Comment a: In the preamble to the fee table, the disclosure states that “[n]o state premium taxes are deducted.” Please consider disclosing the basis for this statement in the prospectus. Note that Item 3(a) of Form N-4, prescribes disclosure that reads, “state premium taxes may also be deducted.”

 Response to Comment a:

 The statement that “[no]
state premium taxes are deducted” is correct. The Registrant is a fraternal benefit society under IRC Section 501(c)(8) and is exempt from all state, county, district, municipal and school taxes or fees.

To provide further clarification, the following underlined phrase has been added to the paragraph.

“The first table describes the fees and expenses that you will pay at the time that you buy the Contract, surrender the Contract, or transfer
cash value between investment options. You pay no sales load when you make additional investments in the Contract. No state premium taxes are deducted because Thrivent is a tax-exempt fraternal benefit
society.”

 Comment b: Include the text of each
footnote at the bottom of the same page on which the footnote item number appears or below the relevant table in which the footnote appears.

Response to Comment b:

The footnotes have been moved to the applicable pages and renumbered accordingly.

Comment c: Footnote 6 and the GLWB:

Comment c(i): Please define both the GLWB Benefit Base and the
Thrivent Income Builder (GLWB) Rider in the “Definitions” section of the prospectus.

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 Response to Comment c(i):

 Definitions have been added for the GLWB Benefit Base and Thrivent Income Builder (GLWB) Rider as follows:

 GLWB Benefit
Base. The GLWB Benefit Base is the amount used for calculating the Guaranteed Annual Withdrawal Amounts and the
GLWB Rider Charge. It cannot be taken as a full or partial surrender and is not payable as part of Death Proceeds.

 Thrivent Income Builder (GLWB) Rider. This is an optional benefit that may be selected at the time of application for
an additional fee. It can provide you with retirement income by guaranteeing specified withdrawals for life. You may withdraw up to a Guaranteed Annual Withdrawal Amount (GAWA) each Contract Year for as long as the Thrivent Income Builder (GLWB) Rider is in force.

 For consistency,
the following two terms have also been added to the “Definitions”:

 Maximum Anniversary Death
Benefit (MADB) Rider. This is an optional benefit that
may be selected at the time of application for an additional fee. It can provide you with an increased death benefit based on the Accumulated Value on a Contract Anniversary.

Thrivent Income Builder (GLWB) Rider Charge. The charge you pay if you add the optional guaranteed lifetime withdrawal benefit at the time of
application. The GLWB Rider Charge will be deducted quarterly from the Accumulated Value.

Comment c(ii): The Fee and Expense Table should refer to the
charge using the exact same name as the feature is elsewhere identified. Currently, the Thrivent Income Builder Charge omits “rider” in the name.

Response to Comment c(ii):

The Fee and Expense Table has been revised to include the word “Rider” in the applicable line. It now appears as follows:

Thrivent Income Builder (GLWB) Rider Charge

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 Comment c(iii):
Please also define the MADB Charge in the Definitions section and add the word, “charge” to the table when referring to the MADB.

Response to Comment c(iii):

The MADB Charge has been defined in the Definitions section and the word “Charge” has been added to the table that refers to the MADB. The
definition has been added as follows:

 Maximum Anniversary Death Benefit (MADB) Rider Charge. The charge you pay if you add the optional death benefit at the time of application. The MADB Rider Charge will be deducted quarterly from the Accumulated Value.

The table has been updated as follows:

Maximum Anniversary Death Benefit (MADB) Rider Charge

Comment c(iv): Please update the disclosure to explain in
Plain English both the rider and the associated charge. Such disclosure should be in the body of the text. Specifically, the disclosure in Footnote 6 related to the Thrivent Income Builder (GLWB) Rider Charge should be included in the section of the
prospectus dedicated to the GLWB rider (p. 28) since that disclosure explains the rider more completely than the earlier prospectus disclosure.

Response to Comment c(iv):

The following underlined sentences have been added to the paragraph above the heading for Periodic Fees and Expenses other than Fund Expenses.

The next table describes the fees and expenses you will pay periodically during the time you own the Contract, not including Portfolio fees and
expenses. In addition, it shows the charges for the optional riders you may add at the time of application. The Maximum Anniversary Death Benefit (MADB) Rider is an optional benefit where the death benefit can increase on each Contract
Anniversary if the Accumulated Value increased. The Thrivent Income Builder (GLWB) Rider is an optional benefit that guarantees income in retirement by providing specified withdrawals for life.

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 The disclosure in Footnote 6 has also been added to the GLWB Rider section.

Comment d: Footnote 7: Terms used in the footnote should be
defined in the footnote or in the Definitions section, and/or cross-referenced to where in the prospectus the terms may be found. For instance, “settlement agreement” appears in disclosure first in the footnote but is not explained nor
defined anywhere in prospectus disclosure.

 Response to Comment d:

 The term “settlement agreement” is in the Settlement Options section on page 54:

Instead of a lump sum, proceeds from death or surrenders of $2,000 or more may be paid under a settlement option by means of a settlement agreement
that we will issue.

 To provide clarification, we have revised Footnote 7 as follows:

7If you are receiving Annuity Income with a guaranteed period, you may elect to receive a full
or partial surrender of the commuted value of the remaining payments, unless the income elected was irrevocable. The value of the remaining payments on any day is based on the interest rate used to determine the income payable plus 0.25%. This
increase of the rate used in the calculation is the Commuted Value Charge. Please see Annuity Provisions – Settlement Options for more information.

In addition, the following definition has been added to the “Definitions” section:

Settlement Option. You may elect to have annuity payments paid to you
under a settlement agreement with Thrivent. Please see Annuity Provisions – Settlement Options for the types of payments offered under the Contract.

 Comment e: Footnote 8 and the Total Annual Portfolio Operating Expenses:

 Comment
e(i): Please note that an N-4 registrant may not show
the range of operating expenses that reflects voluntary fee waivers. As currently drafted, footnote 8 is confusing as to what the TAPOE table is reflecting. Thus,
please adjust the fee table and footnote disclosure to

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conform to N-4 requirements and use plain English in the disclosure description as to what is being reflected in the TAPOE.

Response to Comment e(i): The range of operating expenses in
the table reflects the operating expenses with no fee waivers.

 The paragraph before the table has been revised as follows:

The next table shows the maximum and minimum Total Annual Portfolio Operating Expenses for the year ended December 31, 2019. These are
expenses that are deducted from Portfolio assets, including management fees, distribution or 12b-1 fees, service fees and/or other expenses. Expenses may be higher or lower in future years. More detail
concerning the fees and expenses is contained in the prospectuses for each Portfolio.

 Footnote 8 has been deleted.

Comment e(ii):    The maximum and minimums
disclosed should be those of portfolios offered; furthermore, the impact of both contractual and voluntary reimbursements may not be reflected in the fee table.
Please confirm supplementally to the staff that the range disclosed