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Eversheds Sutherland (US) LLP 1114 Avenue of the Americas, 40th Floor
D: +1 212.389.5080
dodiekent@ eversheds-sutherland.com |
January 26, 2018
VIA EDGAR
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: Commonwealth Annuity and Life Insurance Company
Initial Registration Statement on Form S-1
for Individual Contingent Deferred Annuity Contracts
Dear Commissioners:
On behalf of Commonwealth Annuity and Life Insurance Company (the “Company”), we are transmitting for filing under the Securities Act of 1933, as amended, an initial registration statement on Form S-1 for certain individual contingent deferred annuity contracts to be issued by the Company. Financial statements, exhibits not included therein, and other omitted information will be added by pre-effective amendment.
Please direct questions and comments about this filing to the undersigned at 212.389.5080 or dodiekent@eversheds-sutherland.com.
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Regards, |
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/s/ Dodie C. Kent |
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Dodie C. Kent |
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cc: |
Sarah M. Patterson, Commonwealth Annuity and Life Insurance Company |
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Elizabeth Gioia, Commonwealth Annuity and Life Insurance Company |
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Ronald Coenen Jr., Eversheds Sutherland (US) LLP |
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.