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CORRESP

 Eversheds Sutherland (US) LLP

1114 Avenue of the Americas, 40th Floor

 New
York, NY 10036-7703

 D: +1 212.389.5080

F: +1 212.389.5099

dodiekent@

eversheds-sutherland.com

 July 14, 2023

VIA EDGAR

U.S. Securities and Exchange Commission

 100 F Street, NE

Washington, DC 20549

Attn: Jeffrey Foor, Esq.

 Senior Counsel, Division of Investment
Management –

 Disclosure Review and Accounting Office

Re:   The Penn Insurance and Annuity Company

        PIA Variable Life Account I

        Registration Statement on Form
N-6

         File Nos. 333-269813; 811-23646

Dear Mr. Foor:

This letter, which we have filed as Correspondence, responds to the Staff’s comment letter of April 17, 2023 with regard to the above-referenced
filing. Along with this letter, we have included a revised statutory prospectus (“prospectus”)reflecting our revisions in response to the Staff’s comments. A courtesy blackline reflecting the changes will be provided to the Staff. As
appropriate, the same changes will be made in the Initial Summary Prospectus.

 For
convenience, the Staff’s comments are repeated below in italics, followed by the Company’s response. Capitalized terms used herein have the same meaning as in the registration statement. For product implementation and administrative
reasons, the Company is seeking to “clear” all Staff comments no later than August 1, 2023. At the appropriate time, the Company will file a pre-effective amendment reflecting all revisions and
any currently missing information and file an acceleration request in which it will seek effectiveness no later than September 1, 2023 or as soon as practicable thereafter.

 General

 1.  Comment: Please
confirm that all missing information, including the financial statements and all exhibits, will be filed in a pre-effective amendment to the registration statement. We may have further comments when you supply
the omitted information.

 Eversheds Sutherland (US) LLP is part of a global
legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.

 U.S. Securities and Exchange

Commission

 July 14, 2023

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 2

 Response: We confirm that all missing information, including the financial statements and all
exhibits, will be included in a pre-effective amendment to the registration statement.

2.  Comment: Please clarify supplementally whether there are any types of guarantees or support
agreements with third parties to support any policy features or benefits, or whether the Company will be solely responsible for any benefits or features associated with the Policy.

 Response: There are no guarantees or support agreements with
third parties to support any policy features or benefits. The Penn Insurance and Annuity Company (“the Company”) will be solely responsible for any benefits or features associated with the Policy.

 3.  Comment: Please be
aware that the compliance date for the requirement to use the Inline eXtensible Business Reporting Language (iXBRL) format for the submission of certain required disclosures in the variable contract statutory prospectus was
January 1, 2023. Filings made on or after January 1, 2023 are required to comply with these requirements. See General Instruction C.3.(h) to Form N-6.

 Response: We confirm that the iXBRL format will be used in a
pre-effective amendment to the registration statement prior to effectiveness, as required by General Instruction C.3.(h) to Form N-6.

 4.  Comment: Please ensure
that electronic versions of the summary and statutory prospectuses include appropriate electronic links from each row of the KIT to the corresponding statutory prospectus sections where the specific subject matter is discussed in greater detail. See
Instruction 1(b) to Item 2 of Form N-6. Please note that several existing Penn Mutual products do not currently include the required hyperlinks in the electronic versions of the summary and statutory
prospectuses.

 Response: We will ensure that
electronic versions of the summary and statutory prospectuses, including those relating to other products issued by the Company, include the required electronic links from each row of the KIT to the corresponding statutory prospectus sections where
the specific subject matter is discussed in greater detail in accordance with Instruction 1(b) to Item 2 of Form N-6.

PROSPECTUS

Important Information You Should Consider (pages 5 – 8)

5.  Comment: Please complete all bracketed information. In addition, please confirm all
percentages will be presented to the nearest hundredth of one percent.

 U.S. Securities and Exchange

Commission

 July 14, 2023

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 3

 Response: All bracketed information has been completed and all percentages have been presented to the
nearest hundredth of one percent.

6.  Comment: On page 7, we note disclosure stating, “A policy lapse may have tax
consequences.” Please include disclosure in the prospectus explaining these tax consequences and provide a cross-reference to this disclosure in the key information table.

 Response: We have included disclosure explaining the tax
consequences of policy lapse and provided a cross-reference in the key information table as requested.

Overview of the Protection Variable Universal Life Insurance Policy (pages 9 – 12)

 7.  Comment: The second
paragraph of the Investment Options discussion on page 10 states that, in addition to the Variable Investment Options, the Policy includes “both” a Traditional Fixed Account and a Short-Term Fixed Account. Please revise the disclosure to
also refer to the Dollar Cost Averaging Fixed Account and briefly describe this investment option in this section.

Response: We have revised the disclosure as requested.

8.  Comment: On page 10, disclosure states, “[t]he Fixed Account Options are both designed
to be safe investments that provide fixed returns.” Please clarify that amounts allocated to these options are subject to the claims-paying ability and financial strength of the Company.

 Response: We have included the clarifying disclosure as
requested.

 9.  Comment:
On page 11, under Surrenders and Withdrawals, please clarify in the disclosure the reference to “administrative requirements” that might limit a policy owner from accessing policy value through surrenders or partial withdrawals.

 Response: We have included the clarifying disclosure as
requested.

 Table of Fees and Expenses (pages 13 – 16)

 10. Comment: The Accelerated
Death Benefit Rider states in part that “the interest rate will be the greater of (a) the current 90-day Treasury bill rate, or (b) the current maximum statutory
adjustable policy loan rate.” Please clarify what the current maximum statutory adjustable policy loan rate refers to and where the investor can find this figure.

Response: We have included the clarifying disclosure as requested.

 U.S. Securities and Exchange

Commission

 July 14, 2023

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 4

 11. Comment: With respect to the Estate Preservation Term Rider, please
provide the amount deducted for the representative insured.

Response: We have included the charge for the representative insureds under the Estate Preservation Term Rider as requested.

 Summary of Principal Risks of Investing in the Policy (page 17)

 12. Comment: The discussion on
page 17, under Risk of Lapse, discusses the ability of a policy owner to apply to reinstate the policy within five years from the date of lapse. Please disclose that reinstatement is subject to additional requirements, including payment of a minimum
amount of premium.

 Response: We have included the
disclosure as requested.

 Policy Split Option Rider (pages 36 –
37)

 13. Comment: The
prospectus states that “[t]he cash surrender value of each new policy on the date of the exchange will be the Policy Value on the date of the exchange less any applicable surrender charge for the new policy.” Please confirm that this
statement is correct or whether it should be revised to refer to the “combined cash surrender value of each new policy….”

 Response: We have determined that it would not be accurate
to refer to the “combined” Cash Surrender Value of the two new policies in the subject sentence because the specified percentages of the original Policy’s Policy Value on the date of the exchange are allocated as premium to each of
the two new policies and are therefore subject to percent of premium charges according to the terms of the new policies. We have made clarifying changes to the disclosure.

Accelerated Death Benefit Rider (page 39)

14. Comment: The prospectus states that “[t]he amount you access under this Rider will reduce the
death benefit that is payable under the base Policy upon the death of the second insured to die.” Please clarify if this reduction is dollar-for-dollar or is on
some other basis. Also, in the example, please disclose the remaining death benefit.

Response: We have added the disclosure and revised the example as requested.

 Chronic Illness Accelerated Benefit Rider (page 40)

 15. Comment: In the discussion
of the limits in the Accelerated Benefit Payment, please revise the third and fourth bullet for clarity.

 U.S. Securities and Exchange

Commission

 July 14, 2023

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 Response: We have revised the third and fourth bullets as requested.

 16. Comment: Please explain the
mortality factor used to reduce the remaining death benefit. Please also explain the period over which interest charge is assessed.

Response: We have included the disclosure explaining the mortality factor as requested. We note that the existing disclosure states
that “[u]pon each payment of accelerated benefit, the death benefit will be reduced by an amount greater than the amount of the payment, since the reduction will reflect the amount of the payment, an interest charge on the accelerated
amount, and a mortality factor” (emphasis added). For this reason, we have not included disclosure explaining the period over which interest charge is assessed, as the interest charge reduces the death benefit upon each individual benefit
payment and is not a charge assessed over time.

17. Comment: Please explain supplementally how the figures in the example were derived as we could not
reproduce the figures.

Response:

As described in the prospectus, upon each payment of the chronic illness accelerated benefit, the death benefit is reduced by an amount
greater than the amount of the payment, which reflects the amount of the payment, an interest charge on the accelerated amount, and a mortality factor. The death benefit decrease is equal to the amount of the chronic illness accelerated benefit
payment divided by the actuarial present value of one dollar payable upon the death of the insured, calculated monthly on a continuous basis based on the interest rate and the mortality factor.

 The actuarial present value is designed to quantify the amount that
must be set aside today to pay a future benefit under assumed mortality factors and interest rates. In each policy year this is calculated as: (1 / 1 + the interest rate compounded for the same number of policy years) multiplied by the probability
of survival until that year multiplied by the probability of death in that year. Because the death benefit can be paid in any policy year, the actuarial present value is the sum of this calculation for all policy years until maturity.

 The mortality factor allows a probability of death to be calculated
in each future year while the interest rate determines how much the future death benefit can be discounted for a payment to be made in any given policy year until maturity. The mortality factor is determined by reference to the standard mortality
table attached to the rider, and is based on the time of the first Accelerated Benefit Payment, attained age and issue age. The interest rate will not exceed the greater of (a) the current 90-day Treasury
bill rate, or (b) the current maximum statutory adjustable policy loan rate.

 U.S. Securities and Exchange

Commission

 July 14, 2023

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 Under the assumptions in the example, 0.846138 is the actuarial present value of a one dollar death benefit
to be paid to the insured when he requests a $50,000 chronic illness accelerated benefit payment from his $500,000 Specified Amount. The chronic illness accelerated benefit payment is then adjusted by this amount. The death benefit decrease is equal
to the amount of the chronic illness accelerated benefit payment ($50,000) divided by the actuarial present value of one dollar payable upon the death of the insured (0.846138) = $59,092. The Specified Amount ($500,000) is therefore reduced by
$59,092 = $440,908 remaining death benefit.

 Portfolios Available Under the
Policy (page A-1)

18. Comment: It appears that the Company posts updated portfolio company performance to its website.
Therefore, please include a statement explaining that updated performance information is available and provide a website address and/or toll-free (or collect) telephone number where the updated information may be obtained. See instruction 1(e) to
Item 18 to Form N-6.

Response: We have included the statement in the introductory legend as requested.

 19. Comment: The footnote to
“Current Expenses” should identify each Portfolio Company subject to an expense reimbursement or fee waiver arrangement. See instruction 4 to Item 18 to Form N-6.

 Response: We have removed the subject footnote, as none of
the Portfolios available under the Policy are currently subject to an expense reimbursement or fee waiver arrangement.

We trust these edits and responses fully address all your comments. Please contact me directly should you have any questions.

 Very truly yours,

 /s/ Dodie C. Kent

 Dodie C. Kent

Partner

 Eversheds Sutherland (US) LLP

 cc:    Timothy Graves

 Prospectus

⬛
Survivorship Protection Variable Universal Life

 [    ], 2023

 PROSPECTUS

FOR

 SURVIVORSHIP PROTECTION VUL

a flexible premium variable life insurance policy issued by

THE PENN INSURANCE AND ANNUITY COMPANY

 and funded
through

 PIA VARIABLE LIFE ACCOUNT I

 of

The Penn Insurance and Annuity Company

 PO Box 178,
Philadelphia, Pennsylvania 19105

 800-523-0650

[    ], 2023

 This prospectus describes the Survivorship
Protection Variable Universal Life Insurance policy (the “Policy”), a joint-life, flexible premium variable universal life insurance policy issued by The Penn Insurance and Annuity Company (the “Company”). The Policy is a long
term investment that provides a death benefit upon the death of the second of the insureds to die as well as a cash surrender value which varies with the investment performance of one or more of the mutual fund portfolios that you select. The
available portfolios are listed in Appendix A to this prospectus. The Policy also provides options in the Fixed Account in which amounts may be held to accumulate interest. The life insurance (or death benefit) provided under the Policy will never
be less than the amount specified in the Policy.

 Right to Cancel. If you are a new purchaser of a Policy, you may cancel your Policy within
10 days of receiving it without paying fees or penalties. In some states, this “Free Look” or cancellation period may be longer. If you cancel your Policy, in most states you will receive your policy value, plus any premium charge and
monthly deductions (minus any loans and accrued loan interest). In some states, you will receive a full refund of the amount of any premiums you have paid. You should review this prospectus, or consult with your investment professional, for
additional information about the specific cancellation terms that apply.

 The Securities and Exchange Commission (“SEC”) has
not approved or disapproved of this security or passed upon the accuracy or adequacy of this prospectus. Any representatio