[LOGO]
[THE HARTFORD]
February 13, 2006
VIA OVERNIGHT MAIL | Shane E. Daly |
| Associate Counsel |
| Law Department |
Mr. Michael L. Kosoff | Direct Dial: (860) 843-8336 |
Staff Attorney – Office of Insurance Products | Fax: (860) 843-8665 |
Division of Investment Management
Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549-4644
Re: Post-Effective Amendment No. 4 to the Registration Statement on Form S-6 for Hartford Life Insurance Company Separate Account Twelve (File No. 333-114401) (“Registration Statement”)
Dear Mr. Kosoff:
Enclosed is one copy of the above-referenced Registration Statement that was filed with the Securities and Exchange Commission by Hartford Life Insurance Company (“Hartford”) as Post-Effective Amendment No. 4 on February 13, 2006 pursuant to paragraph (a) of Rule 485 under the Securities Act of 1933.
In addition to the unmarked copy, Hartford has included one copy of the Registration Statement’s prospectus, redlined to show the changes from Post-Effective Amendment No. 3, which was filed on July 20, 2005. Page numbers below refer to the redlined copy of the Registration Statement’s prospectus. Capitalized terms used and not otherwise defined are consistent with the defined terms set forth in the Registration Statement’s prospectus.
Hartford is filing the Registration Statement in order to modify disclosure with respect to Sub-Account Transfers. The new Sub-Account Transfer disclosure appears under the subsection of the prospectus entitled “The Contract” on pages 12 through 14.
Except for the material revisions noted above and as shown in the red-lined copies of the Registration Statements, the disclosure in each Registration Statement is the same as the disclosure in the currently effective Registration Statements that have been previously reviewed by the Commission. Hartford will also include other non-material changes in the Registration Statements in connection with annual update requirements. Therefore, pursuant to Investment Company Act Release No. 13768, Hartford respectfully requests selective review of each Registration Statement.
Financial statements and certain exhibits will be filed by amendment.
If you have any comments or questions regarding these filings, please call me at (860) 843-8336, or Christopher Grinnell at (860) 843-5445.
Very truly yours, |
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/s/ Shane E. Daly | |
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Shane E. Daly |
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Enclosures |
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cc: Christopher Grinnell, Esq. |
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