Pursuant to Rule 477(a) under the Securities Act of 1933, as amended, and on behalf of Great-West and Registrant, we hereby request withdrawal of the above referenced Amendment which was filed on October 22, 2014 (accession no. 0001075796-14-000018). We
request withdrawal of the Amendment due to an inadvertent EDGAR submission error. Registrant has already re-filed the Amendment (accession no. 0001075796-14-000021). This Amendment is not yet effective and Registrant confirms that no securities were sold in connection with this Amendment.
Please direct any question or comment to me at 303-737-3821 or to Ann B. Furman of Carlton Fields Jorden Burt LLP at 202-965-8130.