November 10, 2016
Securities and Exchange Commission
Division of Investment Management
100 F Street NE
Washington, DC 20549
Re: Allianz Life Insurance Company of New York
Pre-Effective Amendment No. 1 to the Registration Statement on Form S-1
File No. 333-213126
Dear Sir/Madam:
Pursuant to Rule 461 under the Securities Act of 1933, the Registrant, Allianz Life Insurance Company of New York and the principal underwriter, Allianz Life Financial Services, LLC, respectfully request that the effective date of the above-referenced Pre-Effective Amendment, filed on October 26, 2016, be accelerated and that the Amendment be declared effective on November 10, 2016, or as soon thereafter as may be practicable.
Allianz represents that it will not market and sell the product filed on this Form S-1 until all Staff comments regarding the Form N-4 registration statement for the product have been resolved, and the Form N-4 registration statement has become effective. Allianz will apply all changes made to the prospectus submitted in the Form N-4 filing to address staff comments to the prospectus in this Form S-1 filing.
If you have any questions or comments, please feel free to contact Stewart Gregg at 763/765-2913 or stewart.gregg@allianzlife.com.
Sincerely,
Allianz Life Insurance Company of New York
By: /s/ Stewart D. Gregg
______________________________________________
Stewart D. Gregg, Senior Counsel
Stewart D. Gregg, Senior Counsel
Allianz Life Financial Services, LLC
By: /s/ Kristine M. Lord-Krahn
______________________________________________
Kristine M. Lord-Krahn, Chief Legal Officer and Secretary
Allianz Life Insurance Company of North America, 5701 Golden Hills Drive, Minneapolis, MN 55416-1297