April 15, 1997
Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
450 Fifth Street, N.W.
Washington, DC 20549
Attention: Ms. Patrice M. Pitts
Branch Chief
RE: United Companies Life Insurance Company
Application Pursuant to Rule 477
to Withdraw Form S-1 Registration Statement
File No. 33-91358
___________________________________________
Dear Ms. Pitts:
This request is made on behalf of United Companies Life Insurance Company (the
"Company"). The Company issues two variable annuity products registered with the
Securities and Exchange Commission. They are individual and group fixed and
variable annuity contracts with market value adjustment ("MVA") options
(collectively, the "Contracts"). Each product has two Registration Statements -
one on Form N-4 (for the variable annuity contracts) and the other on Form S-1
(for the MVA Account options). The Company has redesigned the products.
Effective May 1, 1997, the MVA Account options will no longer be available for
sale.
The Company has filed a Post-Effective Amendment to its registration statement
on Form N-4 (File No. 33-91362) pursuant to Securities Act Rule 485(a) which,
among other things, deletes the disclosure currently required by Form S-1 in its
prospectus. It also filed a request pursuant to Rule 485(b)(1)(ix) with respect
to its other Form N-4 registration statement (File No. 33-95778). The Rule
485(b)(1)(ix) request was granted.
The Company hereby applies to deregister the Form S-1 Registration Statement
(File No. 33-91358), effective May 1, 1997.
Please contact the undersigned with any questions or comments concerning the
above.
Sincerely,
BLAZZARD, GRODD & HASENAUER, P.C.
By: /s/ LYNN KORMAN STONE
__________________________________
Lynn Korman Stone
