VIA EDGAR
December 10, 2010
Ms. Alison White
Senior Counsel, Office of Insurance Products
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: | VAROOM — Request for Acceleration of Pre-Effective Amendment No. 3 to the Registration Statement on Form N-4 (File Numbers 333-166995 and 811-04844) (the “Registration Statement”) |
Dear Ms. White:
Pursuant to Rule 461 under the Securities Act of 1933, as amended, we hereby request that the effective date of the above-captioned Registration Statement be accelerated so that the same will become effective at 9:00 a.m., Eastern Time, today, December 10, 2010, or as soon thereafter as practicable.
In connection with this request, Touchstone Securities, Inc., the underwriter, has also signed this letter requesting acceleration.
Very truly yours,
Touchstone Securities, Inc. |
| Integrity Life Insurance Company | ||
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/s/ Rhonda S. Malone |
| /s/ Kevin L. Howard | ||
By: | Rhonda S. Malone |
| By: | Kevin L. Howard |
Title: | Secretary | Title: | Senior Vice President and General Counsel | |