APP WD/A 1 e1.txt PHL VARIABLE WITHDRAWAL PHOENIX LOGO Kathleen A. McGah, Vice President Phoenix Life Insurance Company, PHL Variable Insurance Company and Phoenix Equity Planning Corporation One American Row Hartford, CT 06102-5056 March 24, 2010 VIA EDGAR U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 Re: PHL Variable Insurance Company PHL Variable Accumulation Account Phoenix Life Insurance Company Phoenix Life Variable Accumulation Account Phoenix Equity Planning Corporation File No. 812-13568 Request for Withdrawal of Amended and Restated Application For An Order of Exemption Pursuant To Section 6(c) of the Investment Company Act of 1940 From Sections 2(a)(32) and 27(i)(2)(A) of the Act and Rule 22c-1 thereunder ("Amended and Restated Application") Dear Sir or Madam: PHL Variable Insurance Company, PHL Variable Accumulation Account, Phoenix Life Insurance Company, Phoenix Life Variable Accumulation Account, and Phoenix Equity Planning Corporation (the "Applicants") hereby respectfully request the withdrawal of the above-referenced Amended and Restated Application, filed with the Securities and Exchange Commission on December 19, 2008. The Application was filed in connection with an offering of certain variable deferred annuity contracts containing premium bonus recapture provisions. The Applicants are currently implementing changes which will impact the distribution plan for this product. Until those changes are underway, the Applicants will not be pursuing exemptive relief with respect to this product. We appreciate your assistance in this matter. If you have any questions regarding this matter, please contact the undersigned at (860) 403-6625. Very truly yours, /s/ Kathleen McGah Kathleen McGah cc: M. Drummey, Counsel for The Phoenix Companies, Inc.