Principal Life Insurance Company 711 High Street, Des Moines, IA 50392 515 247 5111 tel

November 1, 2024

VIA EDGAR

Securities and Exchange Commission100 F Street, NE

Washington, D.C. 20549

Attn: Min S. Oh, Esq.

Senior Counsel

Division of Investment Management – Disclosure Review and Accounting Office

Re:    Principal Life Insurance Company

    Principal® Strategic Income

Post Effective Amendment No. 1 to Registration Statement

File No.: 333-282080

Dear Commissioners:

On behalf of Principal Life Insurance Company (the “Company”), transmitted for filing under the Securities Act of 1933 is post-effective amendment no. 1 (the “Amendment”) to the above-referenced registration statement for Principal® Strategic Income, a single premium index-linked deferred annuity contract (the “Contract”). The primary purpose of the Amendment is to convert the registration statement from Form S-1 to Form N-4 based on the amendments to Form N-4 adopted by the Securities and Exchange Commission on July 1, 2024. See Registration for Index-Linked Annuities and Registered Market Value Adjustment Annuities, Amendments to Form N-4 for Index-Linked Annuities, Registered Market Value Adjustment Annuities, and Variable Annuities; Other Technical Amendments; Release Nos. 33-11294, 34-100450, IC-35273.

In addition, the Amendment also reflects the following noteworthy changes to the Contract:

•Removal of the Variable Account, which was originally designated as a default allocation option in the absence of instructions at the end of a Segment Term. There are no assets attributable to the Contract in the Variable Account, and no assets attributable to the Contract will be in the Variable Account when the amended registration statement becomes effective.

•Adding new Index-Linked Segment Options with a 20% Buffer Rate.

•Adding new Index-Linked Segment Options linked to the performance of the Nasdaq-100 Index.

The Company intends that the registration statement, as amended, will become effective on or about May 1, 2025. The Company intends to file delaying amendments, as necessary, to delay effectiveness until such time. Please direct any questions about this filing to the undersigned at 515-247-6785.

Sincerely,

/s/ Scott Van Wyngarden

Scott Van Wyngarden

Counsel, Registrant

cc: Ronald Coenen Jr., Eversheds Sutherland (US) LLP