Allianz Life Insurance Company of North America

Stewart Gregg

Senior Securities Counsel

Corporate Legal

5701 Golden Hills Drive

Minneapolis, MN  55416-1297

Telephone:  763-765-2913

stewart.gregg@allianzlife.com

www.allianzlife.com

VIA EDGAR

January 8, 2020

Re:Allianz Life Insurance Company of North America

File No. 333-230901

Dear Sir/Madam:

Enclosed for filing please find Post-Effective Amendment No. 3 to the above referenced Registration Statement on Form

S-1.  The primary purpose of this filing is to update prospectus disclosure to reflect the addition of a 3-Year Term to the Index Performance Strategy Crediting Method.

Any additional required prospectus disclosure, exhibits, final executive compensation disclosure, and updated financial information, to include financial statements as of December 31, 2019, will be provided by an additional post-effective amendment on forms S-1 and N-4.

For the convenience of the staff in reviewing the Registration Statement, a red-lined copy of the prospectus is being sent via email to the Office of Insurance Products on the Division of Investment Management.

Manually executed signature pages have been executed prior to the time of this electronic filing and will be retained by the Company for five years.

Please contact me with any questions or comments you may have concerning the enclosed. I can be reached at the following address and phone number: Allianz Life, 5701 Golden Hills Drive, Minneapolis, MN 55416. Telephone: (763)765-2913.

Sincerely,

Allianz Life Insurance Company of North America

By:  /s/ Stewart D. Gregg

            Stewart D. Gregg