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The
United States Securities and
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Exchange
Commission
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100
F. Street, NE
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Washington,
D.C. 20549-0506
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Subject:
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Nationwide
Variable Account – II
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1.
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Nationwide
has increased the amount of the simple interest calculation from
5% to 7%
of the income benefit base for the Lifetime Income
Option;
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2.
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Nationwide
has increased the current charge for the Lifetime Income Option charge
to
0.70% for contracts issued on or after September 1,
2007;
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3.
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Nationwide
is making two settlement options available for the Lifetime Income
Option
when the contract value is zero and the income benefit base under
the
Lifetime Income Option is greater than
zero.
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that
the Separate Account is responsible for the adequacy and accuracy
of the
disclosure in the Post-Effective
Amendment;
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·
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that
comments by the staff of the Securities and Exchange Commission (“SEC”),
or changes to the disclosure in response to SEC staff comments in
the
filings reviewed by the SEC staff, do not foreclose the SEC from
taking
any action with respect to the filing;
and
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·
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that
the Separate Account may not assert SEC staff comments or any related
changes in disclosure as a defense in any proceeding initiated by
the SEC
or any person under the federal securities laws of the United
States.
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