October 31, 2005 Ibolya Ignat, Staff Accountant Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Dear Ms. Ignat: I am writing as a follow-up to our recent telephone conversation. Following please find our responses to your latest inquiries. Please note these responses have added additional information and clarification to the response of October 20, 2005. Question 2 response - Additional clarification Future policy benefits reflected as liabilities of the Company on its balance sheet as of December 31, 2004, included in Item 8 of this report, represent actuarial estimates of liabilities of future policy obligations such as expected death claims on the insurance policies in force as of the financial reporting date. Due to the nature of these liabilities, maturity is event dependent and therefore, these liabilities have been classified as having an indeterminate maturity. The Company is unable to estimate with any certainty the annual expected settlement of the future policy benefits liability. Maturity of this liability is event dependent based on the individual insured under each policy. Death claims and cash value surrenders represent the two most significant events that lead to the payment by the Company. Life insurance products are considered unilateral contracts. The policy owner has ultimate control as regards the contract. Generally, as long as the premiums are paid as required under the policy, the Company cannot cancel the policy contract, only the policy owner can cancel. The contract generally is terminated either by the death of the insured or by a request to surrender the policy by the owner. Either event is not within the control of the Company, making estimating these events with any accuracy or certainty difficult if not impossible. Significant changes in death claims or cash surrender requests could have an impact either positive or negative on the Company's liquidity needs and financial condition. With the above stated, the Company agrees in future filings to estimate to the best of its ability projected future cashflows relating to the liability Future policy benefits. Along with these estimates, the Company intends to include a disclaimer substantially as follows, "estimates of future policy benefits presented are based on historic trend analysis and actuarially determined estimates of future results. Actual results could vary significantly from these estimates resulting in a material impact on the Company's liquidity and financial condition." Question 4 - Additional clarification The Company offers various life insurance products to its customers. We believe these product offerings are similar and represent a single marketplace. All are to provide protection on the life of the individual insured. Each product may have slightly varied options such as face amount of policy available or premium payment options, but all remain similar in nature overall and target the same groups of clients. Future filings will include a statement to the effect a more detailed breakdown of revenues from each product is impracticable. Please contact me should you have any additional questions regarding this supplemental response. Sincerely, /s/ Theodore C. Miller Theodore C. Miller Sr. Vice President
