Separate Account Ii Of Integrity Life Insurance Inactive
Filed: 7 Apr 06, 12:00am
April 10, 2006
VIA EDGAR
William J. Kotapish, Esq.
Chief, Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
100 F. Street N.E.
Washington, D.C. 20549
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 6, 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 in the prospectus regarding the 12b-1 fee related to the Touchstone ETF Funds. The attached addendum is the redlined Guaranteed Minimum Accumulation Benefit section of the prospectus, revised to specifically state the funds have a 12b-1 fee.
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.