REPORT OF INDEPENDENT REGISTERED PUBLIC ACCOUNTING FIRM


To the Audit Committee of
Continental Assurance Company Separate Account (B)

In planning and performing our audit of the financial statements of
Continental Assurance Company Separate Account (B) (the "Separate
Account") as of and for the year ended December 31, 2008, in
accordance with the standards of the Public Company Accounting
Oversight Board (United States), we considered its internal control
over financial reporting, including control activities for
safeguarding securities, as a basis for designing our auditing
procedures for the purpose of expressing our opinion on the
financial statements and to comply with the requirements of Form
N-SAR, but not for the purpose of expressing an opinion on the
effectiveness of Continental Assurance Company Separate Account (B)'s
internal control over financial reporting. Accordingly, we express
no such opinion.

The management of Continental Assurance Company Separate Account (B)
is responsible for establishing and maintaining effective internal
control over financial reporting. In fulfilling this responsibility,
estimates and judgments by management are required to assess the
expected benefits and related costs of controls. A Separate Account's
internal control over financial reporting is a process designed to
provide reasonable assurance regarding the reliability of financial
reporting and the preparation of financial statements for external
purposes in accordance with generally accepted accounting principles.
A Separate Account's internal control over financial reporting
includes those policies and procedures that (1) pertain to the
maintenance of records that, in reasonable detail, accurately and
fairly reflect the transactions and dispositions of the assets of
the Separate Account; (2) provide reasonable assurance that
transactions are recorded as necessary to permit preparation of
financial statements in accordance with generally accepted
accounting principles, and that receipts and expenditures of the
Separate Account are being made only in accordance with
authorizations of management and directors of the Separate Account;
and (3) provide reasonable assurance regarding prevention or timely
detection of unauthorized acquisition, use, or disposition of a
Separate Account's assets that could have a material effect on the
financial statements.

Because of its inherent limitations, internal control over financial
reporting may not prevent or detect misstatements. Also,
projections of any evaluation of effectiveness to future periods are
subject to the risk that controls may become inadequate because of
changes in conditions, or that the degree of compliance with the
policies or procedures may deteriorate.

A deficiency in internal control over financial reporting exists
when the design or operation of a control does not allow management
or employees, in the normal course of performing their assigned
functions, to prevent or detect misstatements on a timely basis.
A material weakness is a deficiency, or a combination of
deficiencies, in internal control over financial reporting, such
that there is a reasonable possibility that a material misstatement
of the Separate Account's annual financial statements will not be
prevented or detected on a timely basis.

Our consideration of Continental Assurance Company Separate
Account (B)'s internal control over financial reporting was for
the limited purpose described in the first paragraph and would not
necessarily disclose all deficiencies in internal control that
might be significant deficiencies or material weaknesses under
standards established by the Public Company Accounting Oversight
Board (United States). However, we noted no deficiencies in
Continental Assurance Company Separate Account (B)'s internal
control over financial reporting and its operation, including
controls for safeguarding securities, that we consider to be a
material weakness as defined above as of December 31, 2008.

This report is intended solely for the information and use of
management and the Board of Directors of Continental Assurance
Company Separate Account (B) and the Securities and Exchange
Commission and is not intended to be and should not be used by
anyone other than these specified parties.



DELOITTE & TOUCHE LLP


Chicago, Illinois
February 20, 2009