July 10, 2015

Deborah D. Skeens

Senior Counsel

Office of Insurance Products

Division of Investment Management

U.S Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549-0506

RE: Registration Statement for Pacific Select VUL-Accumulation Flexible Premium Life Insurance Policy (File Number 333-202248) funded by Pacific Select Exec Separate Account (File Number 811-05563) of Pacific Life Insurance Company, Request for Acceleration

Pursuant to Rule 461 under the Securities Act of 1933, we hereby request on behalf of Pacific Life Insurance Company and Pacific Select Distributors, Inc. (collectively “Registrants”), acceleration of the effective date of the above referenced Registration Statement to July 15, 2015, or as soon thereafter as practicable.

Registrants acknowledge that the Commission staff has not passed upon the accuracy or adequacy of the above-referenced filings. Registrants further acknowledge that: should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing; the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Registrants from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and the Registrants may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Sincerely,
PACIFIC SELECT EXEC SEPARATE ACCOUNT OF PACIFIC LIFE INSURANCE COMPANY
By:	/s/ CHARLENE GRANT
	Charlene Grant
	Vice-President, Counsel
PACIFIC SELECT DISTRIBUTORS, INC.
By:	/s/ ADRIAN S. GRIGGS
	Adrian S. Griggs
	Chief Executive Officer