Northbrook Life Insurance Company
                                3100 Sanders Road
                           Northbrook, Illinois 60062
                               Phone: 847-402-2400

                                January 10, 2000

VIA EDGAR


Ann Vlcek, Esq.
Office of Insurance Products
Room 5130, Mail Stop 5-6
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

     Re:  Northbrook  Variable Annuity Account II ("Registrant")  Post-Effective
          Amendment  No.  22  to  Form  N-4  Registration  Statement  under  the
          Securities Act of 1933, as amended,  and Post-Effective  Amendment No.
          23 under the  Investment  Company Act of 1940 (File No.  033-35412 and
          File No. 811-6116) CIK No. 0000864922

Dear Ms. Vlcek:

On behalf of the  Registrant  and  pursuant  to Rule 477  promulgated  under the
Securities Act of 1933, as amended ("1933 Act"), I hereby request  withdrawal of
the Registrant's  Form N-4 as filed with the Securities and Exchange  Commission
("Commission")  on November 12, 1999. We are requesting  withdrawal  because the
Registrant  subsequently  filed  the  Prospectus  and  Statement  of  Additional
Information  contained  in  post-effective  amendment  number  22 in an  initial
Registration  Statement,  filed on  December  30,  1999  (1933  Act file  number
333-93871), pursuant to the request of the Commission's Staff.

For  ease  of  reference,  additional  information  regarding  the  Registrant's
November 12, 1999 Form N-4 filing is set forth below:

Filing date:               12 November 1999
Received date:             12 November 1999
Accepted date:             12 November 1999
No. of Documents:          8
Test Filing:               No
Confirming Copy:           No
Accession Number:          0000945094-99-000305

For the foregoing reasons, I submit that withdrawal of the Registrant's November
12, 1999 Form N-4 filing would be  consistent  with the public  interest and the
protection of investors, and respectfully request that the Commission grant this
request for  withdrawal.  The cooperation of the  Commission's  Staff is greatly
appreciated in this matter.

Sincerely,


/s/ BRUCE A. TEICHNER
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Bruce A. Teichner
Associate Counsel