0001104659-21-062905.txt : 20210729 0001104659-21-062905.hdr.sgml : 20210729 20210507110218 ACCESSION NUMBER: 0001104659-21-062905 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20210507 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

May 7, 2021

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 Quest Variable Annuity
	File No. 333-250190

	Separate Account A of Pacific Life & Annuity Company (811-09203)
	Initial Registration Statement on Form N-4; Pacific Quest Variable Annuity
	File No. 333-250191

Dear Ms. Choo:

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”), set forth below are responses to Staff comments received on April 12, 2021, received in connection with the above referenced Initial Registration Statements filed on Form N-4 on November 19, 2020, and pre-effective amendment 1 filed on February 10, 2021. All disclosure changes included in this response will be made to all registration statements referenced above, as applicable, by subsequent pre-effective amendment.

Staff Comment: On page 31, please start a new paragraph with the 4^th sentence in the paragraph below the Withdrawal Charge drawdown chart. If accurate, add the following sentence after the first sentence of the new paragraph: “If you take a withdrawal from your Contract, the amount subject to a withdrawal charge is 1) the amount you withdraw plus 2) any amount needed to pay the withdrawal charge.”

Response: We made the requested paragraph edit and added the requested disclosure.

2.	Staff Comment: Please state, if accurate, that the withdrawal request in the “For example” paragraph on page 31 is processed as a gross amount. Also, please state in this example the amount that the Contract Owner would receive as a result of the withdrawal request.

Response: We included the modifications to the example accordingly.

3.	Staff Comment: Underneath the example on page 31, please provide another example similar to the gross example that calculates a withdrawal request processed as a net amount and state what the Contract Owner would receive as a result of the withdrawal request.

Response: We updated the examples of the withdrawal charge calculation accordingly.

I believe the foregoing is responsive to the comments received. If there are any questions, please do not hesitate to reach me at (402) 574-3128. Thank you.

	Sincerely,

	/s/ Michael A. Ramirez

	Michael A. Ramirez