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

April 28, 2020

VIA EDGAR

Securities and Exchange Commission

450 Fifth Street, NW

Washington, DC 20549

RE:Principal Life Insurance Company

Separate Account B

Premier Variable

Registration Statement on Form N-4

File No. 33-44670

I am Counsel for the above-referenced Registrant, and have reviewed the attached post-effective amendment which is being filed pursuant to Rule 485(b) under the Securities Act of 1933. I hereby represent that the amendment does not contain disclosures which would render it ineligible to become effective pursuant to Rule 485(b).

Sincerely,

/s/ Doug Hodgson

Doug Hodgson

Counsel

711 High Street

Des Moines, Iowa 50392-0300

(515) 362-2384 (office)

(866) 496-6527 (facsimile)

hodgson.doug@principal.com