Via Edgar and Electronic Mail
April 23, 2012
Mr. Jeffrey Foor
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
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Re: |
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Variable Annuity Account Seven (Registrant)
SunAmerica Annuity and Life Assurance Company (Depositor)
Post-Effective Amendment to Registration Statement on Form N-4
File Nos. 333-172054 and 811-09003 |
Dear Mr. Foor:
Thank you for the additional comment provided on April 23, 2012, regarding the Post-Effective
Amendment to the Registration Statement on Form N-4 filed pursuant to Rule 485(a) on March 1, 2012
as referenced above. In addition to our letter dated April 17, 2012, we have considered your
comment and provided our response below.
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1. |
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Polaris Portfolio Allocator Program, pages 17-18 |
Comment With respect to the Models and Sample Portfolios, consider adding historical
Models and Sample Portfolios to an appendix to the Prospectus.
Response We have removed the disclosure of the tables describing the current
Polaris Portfolio Allocator Models and Sample Portfolios allocations from page 18
of the prospectus in lieu of adding historical information in an appendix. We have
revised the section titled Important Information about the Polaris Portfolio
Allocator Program, to address where a prospective or existing policy owner may
obtain information regarding past and present Polaris Portfolio Allocator Models
and Sample Portfolio allocations.
We will finalize and print the prospectus on April 24, 2012 and will file all revisions and
all relevant exhibits and financial statements in a post-effective amendment to the registration
statement on or about April 27, 2012. If you have any further questions, please contact me at
310-772-6266.
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Very truly yours,
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/s/ Joseph F. Duronio
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Joseph F. Duronio |
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Counsel |
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