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 Plus Variable Annuity Contract
	Varifund Variable Annuity Account, Amendment No. 31
	Great-West Life & Annuity Insurance Company
	Registration Statement on Form N-4 (File Nos. 333-162272 and 811-05817)
	Request for Withdrawal of Registration Statement

Ladies and Gentlemen:

Pursuant to Rule 477(a) under the Securities Act of 1933, as amended, Great-West Life & Annuity Insurance Company (“GWLA”) and Varifund Variable Annuity Account (“Registrant”) hereby respectfully request the withdrawal of the above-referenced registration statement  including all amendments and exhibits thereto (“Registration Statement”) for the Varifund Plus Variable Annuity Contract (“Contract”), originally filed with the Securities and Exchange Commission on October 1, 2009 (Accession No. 0000851066-09-000058) in connection with the merger of Canada Life Insurance Company of America and GWLA.

This Registration Statement was unnecessarily filed in an attempt to resolve a series/class identifier issue.  The series/class identifier issue was subsequently resolved and Registrant respectfully seeks withdrawal of the Registration Statement.  The Registration Statement was not declared effective.  Accordingly, no securities were sold in connection with the offering for which the Registration Statement was filed.  GWLA and Registrant believe the withdrawal of the Registration Statement to be consistent with the public interest and the protection of investors.

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