Allianz Life Insurance Company of New York

Erik Nelson

Associate General Counsel, Senior Counsel

Corporate Legal

5701 Golden Hills Drive

Minneapolis, MN 55416-1297

Telephone: 763-765-7453

Erik.Nelson@allianzlife.com

www.allianzlife.com

June 8, 2022

Mr. Mark Cowan, Senior Counsel

Securities and Exchange Commission

Division of Investment Management, Disclosure Review Office

100 F Street, NE

Washington, DC 20549-8626

Re: Allianz Life Insurance Company of New York

Pre-Effective Amendment to Registration Statement on Form S-1

Registration Statement No. 333-259863

Mr. Cowan:

Enclosed for filing please find a pre-effective amendment to the above-referenced Registration Statement on Form S-1, which is filed pursuant to the Securities Act of 1933 ("1933 Act"). The purpose of the Registration Statement is to register an updated version of an existing index-linked variable annuity (Index Advantage New York, File No. 333-255308) to reflect prospectus disclosure updates related to recent proposed regulatory changes in the state of New York. The purpose of this pre-effective amendment is to reflect the following:

•

Revisions to conform to the amendments to Form N-4 adopted by the Commission on March 11, 2020. See Updated Disclosure Requirements and Summary Prospectus for Variable Annuity and Variable Life Insurance Contracts, Release No. 33-10765. These revisions were previously reviewed by the Commission staff as part of an amendment to the related Form N-4 registration statement (File No. 333-255394) (Accession No. 0000836346-21-000167), made pursuant to paragraph (a) of Rule 485 under the Securities Act. Such revisions also include those made in response to Commission staff comments.

•	Revisions made in response to Commission staff comments on the Registration Statement, received November 23, 2021.

•	Inclusion of updated financial statements and financial information for the fiscal year ended December 31, 2021, and for the unaudited period ended March 31, 2021 (such financial statements to be added upon amendment).

•	Other non-material revisions and updates.

For the convenience of the staff in reviewing the Registration Statement, a red-lined copy of the prospectus is being sent via email to the Office of Insurance Products of the Division of Investment Management. The red-line reflects changes as compared to the existing version of Index Advantage New York (File No. 333-264350).

The prospectus for the product and a statement of additional information are also being filed on Form N-4 to register the variable, separate account component of the product. The prospectus filed herewith is substantially identical to the prospectus filed on Form N-4.

Manually executed signature pages have been executed prior to the time of this electronic filing and will be retained by the Company for five years. Any disclosures and exhibits not filed herewith will be filed by a pre-effective amendment.

Please contact me with any questions or comments you may have concerning the enclosed. I can be reached at the following address and phone number.

Allianz Life, 5701 Golden Hills Drive, Minneapolis, MN 55416. Telephone: (763)765-7453.

Sincerely,

Allianz Life Insurance Company of New York

By: /s/ Erik T. Nelson

Erik T. Nelson

Associate General Counsel, Senior Counsel

ALLIANZ LIFE INSURANCE CO OF NEW YORK S-1/A