Great-West Life & Annuity Insurance Company

8515 East Orchard Road

Greenwood Village, Colorado 80111

October 5, 2009

VIA EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street NE

Washington, DC 20549

RE:	Varifund Variable Annuity Contract and Varifund Advisor Variable Annuity Contract
	Varifund Variable Annuity Account
	Great-West Life & Annuity Insurance Company
	Registration Statement on Form N-4 (File Nos. 333-162251 and 811-05817)
	Cancellation of Request for Withdrawal

Ladies and Gentlemen:

Varifund Variable Annuity Account (“Registrant”) has determined that the request for withdrawal filed on its behalf on Form RW pursuant to Rule 477 under the Securities Act of 1933 (the “Form RW”) on October 1, 2009 (SEC Accession No. 0000851066-09-000060) was filed in error. Therefore, it is in the best interest of Registrant and the public that the Form RW be withdrawn. Pursuant to Rule 477(a), Registrant hereby requests that the Form RW be withdrawn and the above-referenced Registration Statement remain effective.

We appreciate your assistance. If you have any questions regarding this matter, please contact the undersigned at (303) 737-1130 or Ann Furman at Jorden Burt LLP at (202) 965-8130.

Sincerely,

 Great-West Life & Annuity Insurance Company

 Varifund Variable Annuity Account

  /s/ W. Michael Cirelli

 W. Michael Cirelli

 Counsel

cc: Patrick F. Scott, Esq.

Office of Insurance Products