0000766351-09-000065.txt : 20110516 0000766351-09-000065.hdr.sgml : 20110516 20090521154510 ACCESSION NUMBER: 0000766351-09-000065 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20090521 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VARIABLE ANNUITY ACCOUNT CENTRAL INDEX KEY: 0000768609 IRS NUMBER: 410417830 STATE OF INCORPORATION: MN FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 400 ROBERT ST NORTH CITY: ST PAUL STATE: MN ZIP: 55101-2098 BUSINESS PHONE: 6122234306 MAIL ADDRESS: STREET 1: 400 ROBERT STREET NORTH CITY: ST PAUL STATE: MN ZIP: 55101-2098 FORMER COMPANY: FORMER CONFORMED NAME: MINNESOTA MUTUAL VARIABLE ANNUITY ACCOUNT DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.txt Securian Financial Group, Inc. 400 Robert Street North St. Paul, MN 55101-2098 www.securian.com 651.665.3500 [LOGO] SECURIAN March 16, 2009 Securities and Exchange Commission Sent VIA UPS Overnight Division of Investment Management Office of Insurance Products 100 F Street NE Washington, DC 20549-4644 Attn: Ellen Sazzman Senior Counsel RE: Post-Effective Amendment pursuant to Rule 485(a) Variable Annuity Account File Numbers: 333-91784, 333-140230, 333-111067 and 333-136242 Dear Ms. Sazzman: As discussed March 13, 2009, in our telephone call, thank you for agreeing to consider this additional item. Please find enclosed prospectuses hand-marked to show changes from our last package sent to you on February 27, 2009. No other change has been made. Each change is flagged and the page number is listed below: 333-91784 MOA Advisor (pp. 21, 53, 58, 65, 72) 333-140230 MOA Extra (pp. 22, 53, 58, 64, 71) 333-111067 Waddell & Reed Annuity (pp. 46, 48, 50, 53, 55, 59, 62, 66) 333-136242 MOA Legend (pp. 19, 51, 56, 62, 69) Items 333-91784, 333-140230 and 333-136242 all contain identical changes. They remove the Growth focused portfolio strategy and the Growth ETF Asset Allocation portfolio. The changes to 333-111067 are slightly different because it has different requirements; however, it is accomplishing the same result (i.e., removal of the moderately aggressive growth portfolio from the living benefit options). The prospectuses have been hand-marked to show these changes. You may discard the marked copies sent to you on February 27, 2009. Should you have any questions, please give me a call at 651-665-3708. Sincerely, /s/ Michael P. Boyle Michael P. Boyle Senior Counsel Securian Financial Group provides financial security for individuals and businesses through its subsidiaries including Minnesota Life Insurance Company, Advantus Capital Management, Securian Financial Services and Securian Trust Company.