GREAT AMERICAN RESERVE INSURANCE CO
RW, 2000-04-06
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Blazzard, Grodd & Hasenauer, P.C.
943 Post Road East
Westport, CT 06880
(203) 226-7866


VIA EDGAR


April 6, 2000

Securities and Exchange Commission
Division of Investment Management
Office of Insurance Products
450 Fifth Street, N.W.
Washington, DC 20549

Attention:     Ms. Susan Olson
               Branch Chief

          RE:  Conseco Variable Insurance Company
               Application Pursuant to Rule 477
               to Withdraw Form S-1 Registration Statement
               File No. 333-40301
               ___________________________________________

Dear Ms. Olson:

This  request  is made on behalf of  Conseco  Variable  Insurance  Company  (the
"Company").  The Company issues a variable  annuity product  registered with the
Securities  and  Exchange  Commission.  It is a Group and  Individual  Fixed and
Variable Annuity Contract and Certificate with a market value adjustment ("MVA")
option.  The product has two Registration  Statements - one on Form N-4 (for the
variable annuity  contract) and the other on Form S-1 (for the MVA option).  The
Company has redesigned  the product.  Effective May 1, 2000, the MVA option 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.  333-40309)  pursuant to Securities Act Rule 485(a) which,
among other things, deletes the disclosure currently required by Form S-1 in its
prospectus.

The Company  hereby applies to deregister  the Form S-1  Registration  Statement
(File No. 333-40301), effective May 1, 2000.

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


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