0001104659-20-096844.txt : 20201208 0001104659-20-096844.hdr.sgml : 20201208 20200819150810 ACCESSION NUMBER: 0001104659-20-096844 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20200819 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SEPARATE ACCOUNT A OF PACIFIC LIFE INSURANCE CO CENTRAL INDEX KEY: 0000935823 IRS NUMBER: 000000000 FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: P O BOX 7500 CITY: NEWPORT BEACH STATE: CA ZIP: 92658-7500 BUSINESS PHONE: 7146403743 MAIL ADDRESS: STREET 1: P O BOX 7500 CITY: NEWPORT BEACH STATE: CA ZIP: 92658-7500 FORMER COMPANY: FORMER CONFORMED NAME: SEPARATE ACCOUNT A OF PACIFIC MUTUAL LIFE INS CO DATE OF NAME CHANGE: 19950119 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SEPARATE ACCOUNT A OF PACIFIC LIFE & ANNUITY CO CENTRAL INDEX KEY: 0001074486 IRS NUMBER: 000000000 STATE OF INCORPORATION: CA FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 700 NEWPORT CTR DR CITY: NEWPORT BEACH STATE: CA ZIP: 92660 BUSINESS PHONE: 7146403326 FORMER COMPANY: FORMER CONFORMED NAME: SEPARATE ACCOUNT A OF PM GROUP LIFE INSURANCE CO DATE OF NAME CHANGE: 19981201 CORRESP 1 filename1.htm

Michael A. Ramirez

Attorney

Law Department

Phone: 402-574-3128

Fax: 949-219-3706

Michael.Ramirez@pacificlife.com

August 19, 2020

Ms. Sally Samuel, Branch Chief

Ms. Yoon Choo, Senior Counsel

Office of Insurance Products

Division of Investment Management

U.S. Securities & Exchange Commission

100 F Street, NE

Washington, DC 20549-0506

Re:

Separate Account A of Pacific Life Insurance Company (811-08946)
Initial Registration Statement on Form N-4; Pacific Choice Income
File No. 333-236927

Separate Account A of Pacific Life & Annuity Company (811-09203)
Initial Registration Statement on Form N-4; Pacific Choice Income
File No. 333-236928

Ms. Samuel,

On behalf of Pacific Life Insurance Company (“Pacific Life”), Separate Account A of Pacific Life (811-08946), Pacific Life & Annuity Company (“PLA”), and Separate Account A of PLA (811-09203) (hereinafter collectively referred to as “Registrants”), I am confirming that the following change to the Pacific Choice Income prospectuses will be included in our post-effective Rule 497 definitive materials filing (edited text underlined):

Annuity Options – 3. Joint and Survivor Life

. . . Annuitization becomes effective when the first payment is processed. If one or both Annuitants die prior to the first payment the death benefit would be calculated as described under the DEATH BENEFITS AND OPTIONAL DEATH BENEFIT RIDERS section of the Prospectus and no annuity payment would be made. If both Annuitants pass away after the first payment has processed, payments will cease and there would be no death benefit.

I believe that this is responsive to the final Staff comments provided on Pacific Choice Income. Please do not hesitate to reach me by email or at (402) 574-3128 with any other questions or issues.

	Sincerely,

	/s/ Michael A. Ramirez

	Michael A. Ramirez