[Keyport Life Insurance Company Letterhead]
Keyport Life Insurance Company
125 High Street
Boston, MA 02110
(617) 526-1400
April 6, 1999
VIA EDGAR
The Securities and Exchange Commission
Office of Insurance Products
Division of Investment Management
450 Fifth Street, N.W., Mail Stop 5-6
Washington, D.C. 20549
Re: Keyport Life Insurance Company ("Keyport");
Variable Account A ("Registrant");
Request for Withdrawal of Amendment to Registration Statement on
Form N-4 (File No. 333-75115; 811-7543)
Accession Number: 0001007573-99-000012
CIK Number: 0001007573
Commissioners:
On behalf of Keyport and pursuant to Rule 477 under the Securities Act
of 1933, we respectfully request that the Securities and Exchange
Commission (the "Commission") consent to the withdrawal of Keyport's
Registration Statement on Form N-4 (the "Registration Statement"). This
Registration Statement relates to certain group and individual flexible
purchase payment deferred variable annuity contract (the "Keyport Advisor
Charter Contract").
With or promptly after the filing of this withdrawal, Keyport will
file a withdrawal for a registration statement for another flexible payment
deferred variable annuity contract (the "Keyport Advisor Optima Contract").
The reason for filing the withdrawals is that Keyport discovered it
erroneously indicated on the facing sheet that the Registration Statement
as well as the registration statement for the Keyport Advisor Optima
Contract would become effective 60 days after filing pursuant to Rule
485(a). We discussed the options available for correcting the error with
Mark Amorosi and Kevin Kirchoff of the Commission staff who suggested that
both registration statements be withdrawn and re-filed. Therefore, Keyport
will withdraw and then re-file both registration statements.
By way of background and for the convenience of the staff, the
Registration Statement and the registration statement for the Keyport
Advisor Optima Contract were filed on March 26, 1999 contemporaneously with
two other Registration Statements relating to certain group and individual
flexible purchase payment deferred variable annuity contracts issued by the
Separate Account of Keyport's affiliate, Keyport Benefit Life Insurance
Company ("Keyport Benefit"). The other two registration statements are:
Keyport Benefit Advisor Charter Contracts (File Nos. 333-75157; 811-
08635)
Keyport Benefit Advisor Optima Contracts (File Nos. 333-75155; 811-
08635)
All four registration statements are substantially similar to each
other and as such Keyport and Keyport Benefit requested selective review of
the registration statements. For purposes of the selective review process,
Keyport and Keyport Benefit have prepared courtesy copy filings which
include black-lined versions of the Keyport Benefit registration statements
as well as the registration statement for the Keyport Advisor Optima
Contract marked to show the differences as against the Keyport Advisor
Charter Contract (the subject of this withdrawal). Although the Keyport
Benefit registration statements were filed on March 26, 1999, we will
forward the courtesy black-lined versions of all four registration
statements together via hand-delivery immediately after the facing sheet
errors have been corrected.
On behalf of Keyport, we respectfully submit that a withdrawal of the
Registration Statement is consistent with the public interest and the
protection of investors in light of the circumstances described above.
Very truly yours,
/s/ James J. Klopper
Vice President
