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PIA Variable Life Account I

 Christopher E. Palmer

 +1 202 346 4253

cpalmer@goodwinlaw.com

 Goodwin Procter LLP

 1900 N Street,
NW

 Washington, DC 20036

goodwinlaw.com

 +1 202 346 4000

 December 1, 2023

VIA EDGAR

 Elizabeth Bentzinger

U.S. Securities and Exchange Commission

 Division of Investment
Management

 100 F Street, NE

 Washington, DC 20549

Re:
 The Penn Insurance and Annuity Company

 PIA Variable Life Account I

 Initial Registration Statement on Form N-6

 File Nos. 333-273736;
811-23646

 Dear Ms. Bentzinger:

This letter responds to comments that you provided in a letter dated October 3, 2023, with respect to your review of an initial registration statement on
Form N-6 (the “Registration Statement”) filed on behalf of The Penn Insurance and Annuity Company (the “Company”) and its separate account, PIA Variable Life Account I (the
“Registrant”) for the Accumulation Variable Universal Life Insurance Policy (the “Policy”).

 Set forth below are the comments of the
SEC staff along with the responses thereto by the Company and the Registrant. Undefined capitalized terms used below have the same meaning as in the Registration Statement. The Company and the Registrant are filing today a pre-effective amendment to the Registration Statement (the “Amendment”) to reflect the responses to the comments.

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.

 Response: The Company confirms that the financial statements, all exhibits, and any additional
missing information will be filed in a second pre-effective amendment to the registration statement after receiving any comments to the first pre-effective amendment
filed today.

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.

 PIA Variable Life Account I

Accumulation VUL Insurance Policy

 December 1, 2023

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 2

Response: The Company confirms that there are no guarantees or support agreements with third parties to support any contract
features or benefits and that it will be solely responsible for any benefits or features associated with the Contract.

3.
 Comment: Where a comment is made regarding the disclosure in one location, it is
applicable to all similar disclosure appearing elsewhere in the registration statement, including the summary prospectus. Capitalized terms have the same meaning as in the registration statement unless otherwise indicated.

Response: As applicable, the Company has made corresponding changes throughout the registration statement.

PROSPECTUS

 Cover Page

4.
 Comment: In the first paragraph of the cover page, please make clear in the fourth
sentence that the life insurance and cash surrender value provided under the Policy also include amounts allocated to the fixed account.

Response: The Company has revised the disclosure as requested.

Definitions

5.
 Comment: Please remove the Traditional Loan Account from the list of Fixed Account
Options, as this suggests that the Traditional Loan Account is an investment option under the Policy.

 Please also
clarify or delete the statement that “Policy Value allocated to the Fixed Account Options in most respects is treated in the same manner as Policy Value allocated to the Variable Investment Options.” It is not clear what this means or why
an investor would assume otherwise.

 Finally, please use one term to refer to the Fixed Account’s investment options as the prospectus
refers to both “Fixed Account Options” and “Fixed Account Investment Options.”

 Response: The Company has
revised the disclosure as requested and made corresponding revisions throughout the prospectus and summary prospectus.

6.
 Comment: Please clarify in the definition of Fixed Dollar Cost Averaging Account that
premium allocated to this account will be re-allocated to one or more of the Variable Investment Options and to one or more of the Indexed Fixed Accounts in the Fixed Account Options. Please also clarify that
an investor may transfer Policy Value to the Fixed Dollar Cost Averaging Account for automatic monthly reallocation. Please make corresponding changes throughout the prospectus, including the Fixed Dollar Cost Averaging Account discussion on page 53
of the prospectus.

 PIA Variable Life Account I

Accumulation VUL Insurance Policy

 December 1, 2023

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 3

Response: The Company has revised the disclosure to clarify in the definition of Fixed Dollar Cost Averaging Account that premium
allocated to this account will be re-allocated to one or more of the Variable Investment Options and to one or more of the Indexed Fixed Accounts in the Fixed Account Options as requested and made
corresponding revisions throughout the prospectus and summary prospectus. The Company has not added language stating that the Policy owner may transfer Policy Value to the Fixed Dollar Cost Averaging Account because only premium payments may be
allocated to the Fixed Dollar Cost Averaging Account.

7.
 Comment: In the definition of Indexed Fixed Account, please clarify that this option earns
index credits at the end of a one-year period (or 11-month period for Segments created on the Policy’s first monthly anniversary) based on the change in value of an
index. Please make corresponding changes in the sixth paragraph on page B-1 and in the second paragraph on page B-3 of Appendix B of the prospectus.

 Please also make clear in the definition that the guaranteed minimum interest rate is either 0% or 1%, depending on the
chosen option. Please disclose that even with a guaranteed minimum interest rate, the Policy Value in the Indexed Fixed Account may decrease due to the Asset Charge, and an investor could lose money. Please make corresponding changes throughout the
prospectus when disclosing that Policy Value in the Indexed Fixed Account is subject to a guaranteed minimum interest rate, and disclose this potential risk of loss in the Risks Associated with Investment Options on page 6, the Overview of the
Accumulation Variable Universal Life Insurance Policy, and in the Summary of Principal Risks of Investing in the Policy sections of the prospectus.

Response: The Company has revised the disclosure and made corresponding revisions throughout the prospectus and summary
prospectus to (i) clarify that the Indexed Fixed Account option earns index credits at the end of a one-year period (or 11-month period for Segments created on the
Policy’s first monthly anniversary) based on the change in value of an index; (ii) make clear that the guaranteed minimum interest rate on all non-loaned Indexed Fixed Account segments is 0.00% while
the guaranteed minimum interest rate of the Indexed Loan Account is 1.00%; and (iii) disclose that even with a guaranteed minimum interest rate, the Policy Value in the Indexed Fixed Account may decrease due to the Asset Charge, and an investor
could lose money.

8.
 Comment: Please include the Asset Charge in the list of charges deducted pursuant to the
Monthly Deduction.

 Response: The Company respectfully declines to revise the disclosure as requested
because the Asset Charge is not the same as the other charges listed in the definition of Monthly Deduction. In particular, the definition of “Monthly Deduction” is related to the disclosure in the section of “What Are the Fees and
Charges Under the Policy?” and the “Allocation of Monthly Deduction” which explains how monthly charges applicable to the Policy generally are allocated among investment options. That disclosure does not apply to the Asset Charge,
which applies only to the Indexed Fixed Account.

 PIA Variable Life Account I

Accumulation VUL Insurance Policy

 December 1, 2023

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 4

9.
 Comment: Please revise the Surrender Charge definition to state that the charge also
applies upon a decrease in the Specified Amount within the first five Policy years.

 Response: The Company
has revised the disclosure as requested.

 Important Information You Should Consider

10.
 Comment: Please revise the first paragraph in the Charges for Early Withdrawals section of
the Fees and Expenses table to disclose the maximum surrender charge as a percentage of Specified Amount rather than a dollar amount per $1,000 of Specified Amount. Instruction 2(a) to Item 2 of Form N-6.

 Further, please also remove the parenthetical disclosure stating that a full surrender means an early withdrawal of the
full Net Cash Surrender Value, as well as the statement that the Surrender Charge is shown in the Policy, as these disclosures are neither permitted nor required by Item 2. See General Instruction C.3.(b) of Form
N-6.

 Finally, please move the statement that the Surrender Charge applies upon a decrease in
Specified Amount within the first five years following the purchase of the Policy to the Transactions section of the Fees and Expenses table.

Response: The Company has revised the disclosure as requested and made corresponding revisions to the summary prospectus.

11.
 Comment: In the Transactions section of the Fees and Expenses table, please remove the
disclosure stating that the Surrender Charge will be deducted if the Policy is surrendered within nine years of an increase in the Specified Amount. This has already been appropriately disclosed in the Charges for Early Withdrawals section of the
Fees and Expenses table.

 Response: The Company has revised the disclosure as requested and made
corresponding revisions to the summary prospectus.

12.
 Comment: In the Policy Lapse section of the Risks table, please clarify the reference to
the No-Lapse Requirement, which does not appear to be defined or described in the prospectus.

Response: The Company has revised the disclosure as requested and made corresponding revisions to the summary prospectus.

 PIA Variable Life Account I

Accumulation VUL Insurance Policy

 December 1, 2023

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13.
 Comment: In the Restrictions—Investments table, please disclose that if a Policy loan
is taken while any Policy Value is in the Indexed Fixed Accounts, a 12-month Lockout Period will begin, and during this period, an investor may not transfer Policy Value from the Traditional Fixed Account to
the Indexed Fixed Accounts. Please provide appropriate cross-references. Please also disclose this in the Summary of Principal Risks of Investing in the Policy and in the What is a Policy Loan sections of the prospectus.

Please also revise the fifth bullet to more clearly state in accordance with plain English principles that an investor may only transfer
amounts from an Indexed Fixed Account Option at the end of its term. Please provide appropriate cross-references. Please also disclose this in the Overview of the Accumulation Variable Universal Life Insurance Policy and the Summary of Principal
Risks of Investing in the Policy sections of the prospectus.

 Response: The Company has revised the disclosure as requested
and made corresponding revisions throughout the prospectus and summary prospectus.

14.
 Comment: If true, please disclose in the Restrictions—Optional Benefits discussion
that a change in the Specified Amount, a change in the death benefit option, the addition, deletion, or change of any riders, and/or a change in the insured’s rate class may impact the Policy’s
No-Lapse Feature and may require the payment of additional premiums to maintain the Feature’s guarantee. Please add corresponding disclosure to the Summary of Principal Risks of Investing in the Policy
and to the discussion of the No-Lapse Feature in the prospectus.

Response: The Company has revised the disclosure as requested and made corresponding revisions throughout the prospectus and
summary prospectus.

15.
 Comment: In the Exchanges section of the Conflicts of Interest table, please lowercase
both references to “Policy” in the second sentence to ensure investors are cautioned on the risks of exchanges prior to purchasing the Policy.

Response: The Company has revised the disclosure as requested and made corresponding revisions to the summary prospectus.

Overview of the Accumulation Variable Universal Life Insurance Policy

16.
 Comment: In the Life Insurance Benefit discussion on pages
9-10, please clarify the percentage of the Policy Value in prong (b) of the Option 2 death benefit (e.g., a percentage equal to the minimum necessary for the Policy to qualify as life insurance under
Internal Revenue Code Section 7702).

 Response: The Company has revised the disclosure as requested.

 PIA Variable Life Account I

Accumulation VUL Insurance Policy

 December 1, 2023

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 6

17.
 Comment: As noted elsewhere in the prospectus, the Holding Fixed Account is the default
account for amounts allocated to the Indexed Fixed Accounts on dates other than a monthly Policy anniversary. However, the disclosure on page 10 states that Policy Value may be allocated to the Indexed Fixed Account via the Holding Fixed Account,
the Traditional Fixed Account, and the Short-Term Fixed Account. Please delete this disclosure or explain how and why an investor might route Policy Value to the Indexed Fixed Accounts through the Traditional Fixed Account or the Short-Term Fixed
Account rather than through the designated Holding Fixed Account. Please make corresponding changes to the definition of Fixed Account Options and to the third paragraph of Appendix B.

Please also explain the purpose of the Short-Term Fixed Account, particularly how and why an investor might choose it as a temporary holding
place for the Variable Investment Options. In contrast to the Indexed Fixed Accounts, which necessitate a holding account, the Variable Investment Options are valued daily without any specified start or end dates. Moreover, the Fixed Dollar Cost
Averaging Account is available for those investors who may want to invest periodically in the Variable Investment Options. Please also explain why the Short-Term Fixed Account is considered to have a shorter time period with a corresponding lower
interest rate than the Traditional Fixed Account when both accounts credit interest over a twelve-month period. If true, please explain that the lower rate may be preferable for investors who do not wish to be subject to the Traditional Fixed
Account’s transfer restrictions.

 Response: The Company has revised the disclosure to clarify that the Policy allows a
Policy Owner to allocate Policy Value to the Indexed Fixed Account (via the Holding Fixed Account), the Traditional Fixed Account, and the Short-Term Fixed Account and made corresponding revisions throughout the prospectus and summary prospectus.
The Company has also revised the disclosure to better explain the purpose of the Short-Term Fixed Account. The use of the term “short-term” in the Account’s name is intended to refer to the fact that the Account is fully liquid and
not the interest rate crediting period.

 Table of Fees and Expenses

18.
 Comment: Per Instruction 1(e) to Item 4 of Form
N-6, please ensure that the “When Charge is Deducted” column is used to show when a charge is deducted. We note that the Expense Charge per $1,000 of Specified Amount, Additional Insured Term
Insurance Rider (administrative charges), Early Surrender Value Rider, Cash Value Enhancement Rider, and Supplemental Term Insurance Rider (expense charge) state when the charge is deducted in either the Charge column or Amount Deducted column.

 Response: The Company has revised the disclosure as requested and made corresponding revisions to the
summary prospectus.

 PIA Variable Life Account I

Accumulation VUL Insurance Policy

 December 1, 2023

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19.
 Comm