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Farmers New World Life Insurance Company
Legal Department
3003 77th Avenue S.E.
Mercer Island, Washington 98040

Adam G. Morris
Corporate Counsel
Direct: 206/275-8193
Fax: 206/275-8144

 

June 25, 2008

Sally Samuel, Esq., Senior Counsel
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE.
Washington, D.C. 20549
MS-4644

Re:

Farmers New World Life Insurance Company
Farmers Variable Life Separate Account A (the “Separate Account”)
Pre-Effective Amendment No. 1 to Form N-6 for Farmers EssentialLife Variable Universal Life
File Nos. 333-149540 and 811-09507


Dear Ms. Samuel:

Farmers New World Life Insurance Company (the “Company”) acknowledges the following with respect to the above-referenced filing and request for acceleration of the effective date:

  • should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;
  • the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company, on its own behalf or on behalf of the Separate Account, from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and
  • the Company, on its own behalf or on behalf of the Separate Account, may not assert the actions of the Commission or the staff in declaring the filing effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have any questions or further comments, please call the undersigned at (206) 275-8193.

  Sincerely,

Adam G. Morris
Corporate Counsel

cc:      James P. Brennan, Sr., Esq., Chief Compliance Officer, Farmers New World Life Ins. Co.
Juanita M. Thomas, Esq.