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U.S. Securities and Exchange Commission

Securities Exchange Act of 1934 - Section 15(d)
American Home Assurance Company, et. al.,

October 17, 2005

Response of the Office of Insurance Products
Division of Investment Management

American Home Assurance
Company, et al.

Based on the facts and representations in your letter dated October 14, 2005, and without necessarily agreeing with your legal analysis, we would not recommend enforcement action to the Commission under Section 15(d) of the Securities Exchange Act of 1934 ("Exchange Act") against American Home Assurance Company and National Union Fire Insurance Company of Pittsburgh, Pa. (together the "Guarantors") if, under the circumstances described in your letter, the Guarantors do not comply with the periodic reporting requirements of the Exchange Act. This letter addresses only Exchange Act reporting obligations that could arise in connection with the Guarantors' guarantees of certain variable insurance products as described in your letter and does not address Exchange Act reporting obligations that may arise from time to time as a result of any other activities of the Guarantors. In addition, this letter does not address the obligations of The Variable Annuity Life Insurance Company, American General Life Insurance Company, The United States Life Insurance Company in the City of New York, AIG SunAmerica Life Assurance Company, First SunAmerica Life Insurance Company, AIG Life Insurance Company, and American International Life Assurance Company of New York to file Exchange Act reports (e.g., Form N-SAR) on behalf of the separate accounts that issue the variable insurance products.

This position is based on the facts and representations in your letter. Different facts or representations may require a different conclusion. Further, this response expresses the position of the Division on enforcement only and does not purport to express any legal conclusions on the issues presented.


Jeffrey A. Foor
Senior Counsel

Incoming Letter

The Incoming Letter is in Acrobat format.


Modified: 10/24/2002