PFL LETTERHEAD
May 30, 2000
VIA EDGAR
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
RE: LEGACY BUILDER VARIABLE LIFE SEPARATE ACCOUNT
WITHDRAWAL OF REGISTRATION STATEMENT FILED ON FORM S-6
(FILE NO. 333-68087)
Dear Sir or Madam:
On behalf of the Legacy Builder Variable Life Separate Account (the
"Separate Account"), PFL Life Insurance Company ("PFL") hereby requests,
pursuant to Rule 477 under the Securities Act of 1933, as amended (the "1933
Act"), that the above-referenced registration statement on Form S-6 (File No.
333-68087) be withdrawn. The registration statement was filed on June 8, 1999.
After filing the registration statement, the management of PFL
determined that the modified single premium variable life insurance policy
prototype (the "Policy") that is the subject of the registration statement in
File No. 333-68087 would not be offered or sold to the public. PFL has neither
offered nor sold the Policy nor does it intend to offer or sell it in the
future.
In addition, the management of PFL has decided to file an application
with the Securities and Exchange Commission pursuant to Section 8(f) of the
Investment Company Act of 1940, as amended (the "1940 Act"), to request an order
that the Separate Account through which the Policy had invested cease to be
registered as an investment company under the 1940 Act.
Please direct any questions regarding the enclosed to Priscilla Hechler
at727-299-1747. Thank you for your assistance with this matter.
Very truly yours,
WESTERN RESERVE LIFE ASSURANCE CO. OF OHIO
By: /s/ PRISCILLA I. HECHLER
Priscilla I. Hechler
Assistant Vice President
and Assistant Secretary
cc: Kimberly A. Scouller, Esq.
Stephen E. Roth, Esq.
Mary Jane Wilson-Bilik, Esq.
Frank Camp, Esq.