Separate Account Ii Of Integrity Life Insurance Inactive
Filed: 4 Apr 06, 12:00am
April 5, 2006
VIA EDGAR
William J. Kotapish, Esq.
Chief, Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549-0506
RE: Integrity Separate Account II
File Nos. 33-51268 and 811-07134
Response to Staff Comments
Dear Mr. Kotapish:
This letter is in response to an additional comment received from the Securities and Exchange Commission staff (“Staff”) on April 3, 2006, on a filing by this Registrant pursuant to Rule 485(a) under the Securities Act of 1933, Post-Effective Amendment No. 25 to Integrity Separate Account II Registration Statement on Form N-4, filed on February 17, 2006.
The Staff requested clarification regarding certain charges related to the Guaranteed Minimum Accumulation Benefit (“GMAB”). The cost of the GMAB is 0.60%, which is the insurance company charge for the rider intended to cover the costs, expenses and risks associated with the GMAB. The expenses charged at the fund level will not differ whether the fund is used in conjunction with the GMAB Option or not. The fund fees will include a 0.25% 12b-1 fee (“service fee”), assuming approval by the Touchstone Funds’ Board of Directors at an upcoming meeting.
We hope this response adequately addresses the Staff’s concerns. Further, we hereby acknowledge that should the Securities and Exchange Commission (“Commission”) or its Staff, acting pursuant to delegated authority, declare this filing effective, it does not foreclose the Commission from taking any action with respect to the filing. The action of the Commission or its Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve Integrity Life Insurance Company from its full responsibility for the adequacy and accuracy of
the disclosure in the filing. Integrity Life Insurance Company may not assert the action of the Commission, or its Staff, acting pursuant to delegated authority, in declaring the filing effective as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
If there are any questions, please do not hesitate to call me at 513-629-1854, or e-mail at rhonda.malone@wslife.com
| Sincerely, | |
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| /s/ Rhonda S. Malone |
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| Rhonda S. Malone | |
| Associate Counsel - Securities | |
| Integrity Life Insurance Company | |
c: Allison T. White, Esq. Via Overnight Mail
Kevin L. Howard, Esq.
Michael Berenson, Esq.