Response Letter

0001193125-08-184241.txt : 20110802 0001193125-08-184241.hdr.sgml : 20110802 20080826144339 ACCESSION NUMBER: 0001193125-08-184241 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20080826 FILER: COMPANY DATA: COMPANY CONFORMED NAME: WRL SERIES LIFE ACCOUNT CENTRAL INDEX KEY: 0000778209 IRS NUMBER: 000000000 STATE OF INCORPORATION: OH FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 570 CARILLON PARKWAY CITY: ST PETERSBURG STATE: FL ZIP: 33716 BUSINESS PHONE: 7272991800 MAIL ADDRESS: STREET 1: 570 CARILLON PARKWAY CITY: ST PETERSBURG STATE: FL ZIP: 33716 CORRESP 1 filename1.htm Response Letter

(WRL Letterhead)

Via EDGAR

August 26, 2008

Mr. Craig Ruckman

Office of Insurance Products

Securities and Exchange Commission

100 F Street NE

Mail Stop 4644

Washington DC 20549-4644

Re:	Post-Effective Amendment No. 13

Western Reserve Life Assurance Company of Ohio

WRL Series Life Account

WRL Freedom Elite Builder (File No. 333-58322/811-4420)

Filer CIK No.: 0000778209

Dear Mr. Ruckman:

This letter is in response to the Staff’s comments regarding the registrant’s 485(a) filing (Post-Effective Amendment No. 13) on June 27, 2008. The Staff requested a supplemental response for two items included in the comments. As noted in our call on August 21, 2008, we are submitting our supplemental responses via an EDGAR Correspondence filing. For your convenience, each comment requiring a supplemental answer is stated below, followed by the Registrant’s response. All other comments provided by the Staff were addressed in the Registrant’s Post-Effective Amendment No. 14 filing that was submitted earlier today.

COMMENT:

Please clarify supplementally whether there are any types of guarantees or support agreements with third parties to support any of the company’s guarantees under the policy or whether the company will be primarily responsible for paying out associated guarantees with the policy.

Response:

As noted in our teleconference, and restated herein, the company is primarily responsible for any associated guarantees with the Policy.

COMMENT:

Please confirm supplementally that the contract name on the front cover page of the prospectus is and will continue to be the same as the EDGAR class identifiers associated with the contract.

Response:

As noted in our teleconference, and restated herein, the name of the product that appears on the front cover of the filed prospectus will continue to be the same as the EDGAR classification.

Please do not hesitate to contact the undersigned at (727) 299-1830 or Gayle A. Morden at (727) 299-1747 if you have any questions regarding our responses.

Sincerely,

/s/ Arthur D. Woods

Arthur D, Woods

Vice President and Senior Counsel

cc:	Mary Jane Wilson-Bilik, Esq.