COVER 9 filename9.htm IPVA New-Transmittal-042915


April 29, 2015

Via EDGAR

Michelle Roberts
Senior Attorney
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
100 F Street, NE
Washington D.C. 20549

RE:    Principal Life Insurance Company
Separate Account B
Principal Investment Plus Variable Annuity
Post-Effective Amendment No. 8 to Registration Statement on Form N-4
File No.: 811-02091, 333-188293

Dear Ms. Roberts:

Pursuant to Rule 485(a) under the Securities Act of 1933, as amended (the 1933 Act), the above-named Registrant is filing with the Securities and Exchange Commission (the Commission) a post-effective amendment to the Registrants registration statement on Form N-4 under the 1933 Act and the Investment Company Act of 1940 (the Amendment) for the above-named Contract.

This Amendment is being made to update financial information, underlying mutual fund operating expenses and the accompanying examples.

The Amendment is not being filed to update or amend the prospectuses or statement of additional information for the Registrants other variable annuity contracts.

The Amendment contains a facing sheet, a Prospectus, a Statement of Additional Information, Part C, and a signature page.

We understand that the Registrant is responsible for the accuracy and adequacy of the disclosure in the filing and that staff comments or our changes to the disclosure in response to the staff comments do not foreclose the Commission from taking any action with respect to the filing. In addition, the Registrant may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please call me at 515-362-2384 if you have any questions.

Sincerely,
/s/ Doug Hodgson
Doug Hodgson
Counsel, Registrant
711 High Street
Des Moines, IA 50392-0300
(515) 362-2384
Hodgson.Doug@principal.com