ThZeal - The Zeal

CORRESP 1 filename1.txt April 27, 2009 VIA EDGAR, ELECTRONIC MAIL AND U.S. MAIL Securities and Exchange Commission Division of Investment Management 100 F Street N.E. Washington, D.C. 20549 Re: Variable Annuity Account Seven ("Registrant") AIG SunAmerica Life Assurance Company ("Depositor") Polaris II A-Class Platinum Series Variable Annuity Post Effective Amendments on Form N-4 File Nos. 333-137882 and 811-09003 Ladies and Gentlemen: On behalf of the Registrant and Depositor, we are transmitting for filing pursuant to the Securities Act of 1933 ("1933 Act"), Post-Effective Amendment No. 14, which also constitutes Amendment No. 15 under the Investment Company Act of 1940, as amended, to Registrant's Form N-4 Registration Statement for the Polaris II A-Class Platinum Series variable annuity contracts. The Registrant and its distributor SunAmerica Capital Services, Inc. ("SACS") respectfully request, consistent with Rule 461(a) under the 1933 Act, that the Commission, pursuant to delegated authority, grant acceleration of the effective date of this filing and that such Registration Statement be declared effective at 9:00 a.m., Eastern Time, on April 30, 2009, or as soon as practicable thereafter. Depositor, Registrant and SACS are aware of their obligations under the 1933 Act. Depositor and Registrant acknowledge that: - Should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; and - The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve Depositor and Registrant from full responsibility for the adequacy and accuracy of the disclosure in the filing; and - Depositor and Registrant may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Please contact Manda Ghaferi at (310) 772-6545 if you have any questions or need more information. Sincerely, AIG SUNAMERICA LIFE ASSURANCE COMPANY By: /s/ Mallary L. Reznik ---------------------------------------------------------- Mallary L. Reznik, Senior Vice President & General Counsel SUNAMERICA CAPITAL SERVICES, INC. By: /s/ Mallary L. Reznik ---------------------------------------------------------- Mallary L. Reznik, Vice President cc: Jeff Foor, Esq. April 28, 2009 VIA EDGAR AND FEDERAL EXPRESS Mr. William Kotapish Division of Investment Management Securities and Exchange Commission 100 F Street, N.W. Washington, D.C. 20549 Re: Variable Annuity Account Seven ("Registrant") AIG SunAmerica Life Assurance Company ("Depositor") Polaris II A-Class Platinum Series Variable Annuity Post Effective Amendments on Form N-4 File Nos. 333-137882 and 811-09003 Dear Mr. Kotapish: We are contacting you regarding Post-Effective Amendment No. 14 and No. 15 (the "Amendments") filed on April 27, 2009, for the file numbers referenced above on behalf of the Registrant and Depositor pursuant to the Securities Act of 1933 ("1933 Act") and the Investment Company Act of 1940 ("1940 Act"). The purpose of the filing is to offer a new living benefit ("MarketLock For Life"), modify a living benefit ("MarketLock Income Plus" and "MarketLock For Life Plus"), and modify the existing death benefits (collectively, the "New Initiatives"). In addition, the Amendments modify the "Other Information" section of the prospectus pertaining to disclosure in the Separate Account and General Account sub sections, and incorporate the Staff's comments to the same (collectively, the "Company Disclosure"). The revisions in the Amendments with respect to the New Initiatives and Company Disclosure are also substantially identical to revisions Depositor intends to make in several other variable annuity contracts registered on Form N-4 ("Other Filings"). Pursuant to Rule 485(b)(1)(vii), we request to use the Amendments as the template for the Other Filings. Below are the file numbers for the Other Filings to which we propose adding the New Initiatives:

Mr. William Kotapish April 28, 2009 File Nos. 333-137882 and 811-09003 Page 2 Below are the file numbers for the Other Filings to which we propose adding the Company Disclosure:

Mr. William Kotapish April 28, 2009 File Nos. 333-137882 and 811-09003 Page 3 Any revisions made to the Amendments relating to the New Initiatives and the Company Disclosure and all SEC comments will be effectively incorporated into the Other Filings. No other material changes would be made to the Other Filings that would render the filings ineligible to become effective pursuant to Rule 485(b). The Depositor and Registrant acknowledge that: - Should the Commission or the Staff, acting pursuant to delegated authority, permit the other filings to go effective pursuant to Rule 485(b)(1)(vii), it does not foreclose the Commission from taking any action with respect to the filing; and - The action of the Commission or the Staff, acting pursuant to delegated authority, in permitting the Other Filings to go effective pursuant to Rule 485(b)(1)(vii), does not relieve Depositor and Registrant from full responsibility for the adequacy and accuracy of the disclosure in the Other Filings; and - Depositor and Registrant may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. Should you have any questions regarding this filing, please do not hesitate to contact me at (310) 772-6545. Very truly yours, /s/ Manda Ghaferi Manda Ghaferi Assistant General Counsel cc: Jeffrey A. Foor -- Office of Insurance Products