1851 Securities, Inc.

One American Row

Hartford, CT 06102

April 11, 2012

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

RE: PHL Variable Insurance Company

Post-Effective Amendment No. 10 to Form S-1 on Form S-3

File No. 333-87218

To the Commission Staff:

Pursuant to Rule 461 under the Securities Act of 1933, the undersigned Principal Underwriter requests acceleration of the effectiveness of the above captioned registration statement to April 30, 2012.

Thank you for your kind consideration in this matter.

Sincerely,

/s/ John H. Beers

John H. Beers

Vice President and Secretary

1851 Securities, Inc.