SUN LIFE N Y VARIABLE ACCOUNT C, 497J, 2000-05-12

SUN LIFE N Y VARIABLE ACCOUNT C
497J, 2000-05-12

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May 12, 2000


Securities and Exchange Commission
One Judiciary Plaza
450 Fifth Street, N.W.
Washington, D.C. 20549

     Re:   Sun Life (N.Y.) Variable Account C ("Registrant")
           Post-Effective Amendment No. 5 (the "Post-Effective Amendment") to
           Registration Statement on Form N-4 (File No. 333-05037) (the
           "Registration Statement")


Ladies and Gentlemen:

     In lieu of filing under paragraph (c) of Reg. ss.230.497 of the Securities
Act of 1933, Sun Life (N.Y.) Variable Account C ("Registrant") hereby certifies
in accordance with paragraph (j) of such Reg. ss.230.497 that:

     (1)  The form of Supplement dated May 5, 2000 to the Profile dated April
          17, 2000 and the Prospectus dated April 17, 2000 that would have been
          filed under paragraph (c) of Reg. ss.230.497 would not have differed
          from that contained in the Post-Effective Amendment, and

     (2)  The text of the Post-Effective Amendment, which is the most recent
          amendment to the Registration Statement, was filed electronically on
          May 5, 2000.


                                              SUN LIFE (N.Y.) VARIABLE ACCOUNT C

                                              (Registrant)
                                              /s/ SANDRA M. DADALT
                                              Sandra M. DaDalt, Esq.
                                              Senior Counsel