February 12, 2021

Via EDGAR TRANSMISSION

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549


			Re:			Symetra Life Insurance Company (the “Company”) Initial Registration Statement on Form S-1 File No. 333-______

Commissioners:

The Company is transmitting for filing under the Securities Act of 1933, as amended, an initial registration statement on Form S-1 for certain index-linked deferred annuity contracts to be issued by the Company (the “Registration Statement”).

Required exhibits not filed with or incorporated by reference into the Registration Statement, as well as other omitted information, will be included in a pre-effective amendment to the Registration Statement.

Please direct any questions or comments regarding the Registration Statement to the undersigned at 515-471-8159 or at darlene.chandler@symetra.com.

Sincerely,

/s/ Darlene K. Chandler

Darlene K. Chandler

Senior Vice President & Associate General Counsel

Symetra Life Insurance Company

cc: Jacqueline M. Veneziani, General Counsel, Symetra Life Insurance Company

Dodie Kent, Eversheds Sutherland (US) LLP

Symetra Life Insurance Co S-1