AIG Life and Retirement 21650 Oxnard Street Suite 750 Woodland Hills, CA 91367 www.aig.com |
March 29, 2021
VIA EDGAR & E-MAIL
Mr. Jeff Foor U.S. Securities and Exchange Commission Division of Investment Management 100 F. Street. N.E. Washington, D.C. 20549 | |
Manda Ghaferi Vice President & Deputy General Counsel T + 1 310 772 6545 MGhaferi@aig.com |
Re: | Variable Separate Account (“Registrant”) |
American General Life Insurance Company (“Depositor”)
Polaris Platinum III Variable Annuity
Post-Effective Amendment No. 26 and Amendment No. 26 on Form N-4
File Numbers: 333-185762 and 811-03859
Dear Mr. Foor:
We are contacting you regarding the above Post-Effective Amendment No. 26 (the “Template filing”) filed pursuant to Rule 485(a) on January 15, 2021.
The purpose of the Template filing is to conform to the new disclosure and format requirements of the amended Form N-4. The format and type of the disclosure changes made in the Template filing are substantially identical to disclosure changes that we intend to make in Depositor’s other variable annuity products registered on Form N-4 (“Replicate filings”).
We believe the Template filing is a fair representation of the Replicate filings and reflects the depositor’s overall approach to complying with the new and amended items required under the amended Form N-4.
The substance of the disclosures in the Replicate filings were previously reviewed by the SEC staff or are otherwise consistent with the requirements of Rule 485(b). One of the Replicate filings is an advisory share-class version of the Template filing. We will incorporate applicable changes to the advisory share-class version to resolve any comments the SEC staff may provide specifically to such Replicate filing. The advisory share-class contract (Polaris Advisory) does not allow the advisory fees to be deducted from the contract value.
Pursuant to Rule 485(b)(1)(vii), we respectfully request to use the format and type of the disclosure changes in the Template filing for the Replicate filings.
Below are the file numbers for the Replicate filings:
Issuing Life Company: American General Life Insurance Company
Product Name |
File Numbers | |
Polaris Preferred Solution |
333-185778 and 811-03859 | |
Polaris Advisory |
333-223017 and 811-03859 | |
Polaris Retirement Protector |
333-185787 and 811-03859 | |
Polaris |
333-185798 and 811-03859 | |
Polaris II |
333-185799 and 811-03859 | |
Polaris Choice IV |
333-185784 and 811-03859 | |
Polaris Choice II Polaris Choice III |
333-185837 and 811-03859 | |
Polaris Choice III |
333-185840 and 811-03859 |
Polaris Platinum II |
333-185838 and 811-03859 | |
Polaris Platinum II |
333-185775 and 811-03859 | |
Seasons Select II |
333-185804 and 811-07727 | |
Polaris Platinum O-Series |
333-185790 and 811-09003 | |
Polaris II A-Class Polaris II A-Class Platinum Series |
333-185807 and 811-09003 | |
Polaris II A-Class Platinum Series |
333-185795 and 811-09003 |
Issuing Life Company: The United States Life Insurance Company in the City of New York
Product Name |
File Numbers | |
Polaris Platinum III |
333-178841 and 811-08810 | |
Polaris Preferred Solution |
333-178845 and 811-08810 | |
Polaris Retirement Protector |
333-178849 and 811-08810 | |
Polaris Platinum O-Series |
333-178843 and 811-08810 |
Issuing Life Company: The Variable Annuity Life Insurance Company
Product Name |
File Numbers | |
Polaris Platinum Elite |
333-201800 and 811-03240 |
The Depositor and the Registrant undertake to make the following representations in support of this request:
• | The format and type of the disclosure changes in the Template filing have been made to comply with the amendments to Form N-4 and are substantially identical to the format and type of disclosure changes that will be made in the Replicate filings. |
• | The Replicate filings will incorporate changes made to the disclosure included in the Template filing to resolve any staff comments thereon. |
• | The Replicate filings will not include any other changes that would otherwise render them ineligible for filings under rule 485(b). |
Should you have any questions or need any additional information concerning the Registration Statement, please do not hesitate to contact me at (310) 772-6545.
Very truly yours,
/s/ Manda Ghaferi
Manda Ghaferi