RW 1 drw.txt WITHDRAWAL OF REGISTRATION STATEMENT STEPHEN E. ROTH DIRECT LINE: 202.383.0158 Internet: sroth@sablaw.com March 4, 2003 VIA EDGAR U.S. Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: MONY America Variable Account L File No. 333-103552 Accession No. 0001021408-03-003632 Withdrawal of Registration Statement Pursuant to Rule 477 Commissioners: On behalf of MONY America Variable Account L (the "Variable Account") of MONY Life Insurance Company of America ("MLOA"), we hereby request that the above-referenced registration statement under the Securities Act of 1933 (Form N-6, File No. 333-103552) be withdrawn, pursuant to Rule 477 under that Act. On March 3, 2003, the registration statement was inadvertently submitted and accepted via EDGAR as an initial registration statement on N-6, the incorrect filing type. On March 3, 2003, the registration statement was re-submitted and accepted via EDGAR as a 485APOS, the correct filing type (File No. 333-06071). The initial registration statement on N-6 (File No. 333-103552) never became effective and no securities were sold in connection with the registration statement. It should be noted that the Variable Account is a registered unit investment trust under the Investment Company Act of 1940 (the "1940 Act") (File No. 811-04234). The Variable Account is the funding vehicle for different classes of variable life insurance policies issued by MLOA, registered separately under the Securities Act of 1933. Therefore, the Variable Account will maintain its registered status under the 1940 Act. U.S. Securities and Exchange Commission March 4, 2003 Page 2 of 2 If there are any questions or comments concerning this request, please call me at (202) 383-0158 or Pamela Ellis at (202) 383-0566. Sincerely, Stephen E. Roth cc: Ellen Sazzman, Esq. Haroula Ballas, Esq. Pamela K. Ellis, Esq.