November 9, 2000
Securities and Exchange Commission
450 Fifth Street, NW
Washington, D.C. 20549-10014
ATTN: Document Control - EDGAR
RE: Pre-Effective Amendment No. 1 on Form S-6 (File No. 333-44644)
And Amendment No. 7 to Form N-8B-2
IDS Life of New York Account 8
Investment Company Act No. 811-05213
Dear Commissioners:
IDS Life of New York Account 8, the Registrant, has filed Pre-Effective
Amendment No. 1, dated on or about November 9, 2000, to the above-referenced
Form S-6 Registration Statement. Pursuant to Rule 461, the Principal Underwriter
for the Registrant, American Express Financial Advisors Inc. now respectfully
requests that the effective date of the Registration be accelerated and that the
Registration Statement be declared effective on November 20, 2000 or as soon as
practicable thereafter.
Yours Truly,
AMERICAN EXPRESS FINANCIAL ADVISORS INC.
(Principal Underwriter)
/s/ Teresa J. Rasmussen
Teresa J. Rasmussen
Vice President and Managing Counsel
