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Lisa Proch Talcott Resolution Law Group The Hartford* 1 Griffin Road North Windsor, CT 06095-1512 Tel. 1-860-547-4390 lisa.proch@thehartford.com *As administrator for The Registrant
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April 26, 2018
Mr. Sonny Oh
Senior Counsel
U.S. Securities and Exchange Commission
Division of Investment Management – Disclosure Review and Accounting Office
100 F Street, N.E.
Washington, D.C. 20549
Re: Union Security Insurance Company ("Registrant")
File No. 333-224347 Empower
File No. 333-224394 Masters
Masters+
File No. 333-224346 Triple Crown
File No. 333-224393 TD Waterhouse
Union Security Life Insurance Company of New York ("Registrant")
File No. 333-224349 Masters
File No. 333-224348 TD Waterhouse
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a. | COMMENT: Under the Calculation of Registration Fee table, please revise "Proposed Account to be Registered" to "Amount to be Registered." |
RESPONSE: Registrants hereby represent that we will revise the disclosure.
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b. | COMMENT: In the Calculation of Registration Fee table in the "Amount to be Registered" column, please state the amount of shares that are being carried over. |
RESPONSE: Registrants hereby represent that we will state the amount of shares to be carried over.
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c. | COMMENT: In the Calculation of Registration Fee table in the "Amount to be Registered" column, please footnote disclosure required by Rule 415(a)(6). |
RESPONSE: Registrants hereby represent that we will include the disclosure by Rule 415(a)(6) in the footnote.
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d. | COMMENT: On the facing page, please state required disclosure pursuant to Rule 429. |
RESPONSE: Registrants hereby represent that we will include the required disclosure.
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e. | COMMENT: Please state the required disclosure pursuant to Rule 481(b)(1). |
RESPONSE: Registrants hereby represent that we will include the required disclosure.
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f. | COMMENT: Under Item 13, please break out the list of expenses. |
RESPONSE: Registrants hereby represent that we will break out the list of expenses.
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g. | COMMENT: Pursuant to Item 17, please ensure all required undertakings are provided. |
RESPONSE: Registrants hereby represent that we will include the required undertakings disclosure.
Sincerely,
/s/ Lisa Proch
Lisa Proch
Vice President,
Assistant General Counsel