[HORACE MANN LOGO] Retirement Annuities and Life, Auto,
Homeowners and Group Insurance
October 12, 2006
U.S. Securities and Exchange Commission
Attention: Tony Burak and Allison White
100 F Street, NE
Washington, DC 20549
Re: Horace Mann Life Insurance Company
Horace Mann Life Insurance Group Annuity Separate Account
Initial Registration Statement on Form N-4
File Nos. 333-136513 and 811-21939
Dear Mr. Burak and Ms. White:
In response to your telephone conversations with Patrice Pitts of Sutherland,
Asbill and Brennan on October 2, 2006 and October 11, 2006 we offer the
following;
1. Why are only the last two years of the Financial Highlights for
the Separate Account audited?
This Separate Account was created on March 1, 2002 and was registered
on August 11, 2006. As such we have provided the required two years of audited
financials for the statements of net assets, statements of operations, changes
in net assets and the financial highlights. Since the Financial Highlights are
supposed to cover 5 years or since inception of the Separate Account we included
the two additional years as unaudited information.
2. The directions from the AICPA Audit and Investing Guide for
Investment Companies, paragraph 10.58, indicates there should be
footnotes for the expense ratio, return ratio and the investment
income ratio in the Financial Highlights for the Separate
Account. Why do you not include a footnote for the investment
income ratio?
We inadvertently omitted the footnote for the investment income ratio. We will
add the following footnote to all future financials: "These ratios represent
investment income expressed as a percentage of Average Net Assets for the period
indicated."
3. In the summary section under "What was the status of the group
Contract and the Separate Account before the date of this
prospectus?" change the 3rd sentence to read "The Company has
recently determined, however, that the 403(b) Plan is a type of
'governmental plan' funded by an annuity contract that is not
exempted from registration as a security." Also, in the last
sentence of this section, add the page number where the
reference can be found.
The Horace Mann Companies 1 Horace Mann Plaza Springfield, Illinois 62715-0001
217-789-2500 www/horacemann.com
We have made these requested changes.
4. Under the section titled "Registration Statement" delete the 2nd
sentence and combine the third and 4th sentences so they read
"This prospectus does not contain all information set forth in
the registration statement, its amendments and exhibits, which
include the Group Contract, the Certificates thereunder, and
such instruments as filed.
We have made these requested changes.
5. Why is the first paragraph of disclosure included under the
heading "Condensed Financial Information"? Would the
accumulation unit values presented in Appendix A have been
different if the Separate Account had been registered?
Among other things, Item 4 of Form N-4 ("Condensed Financial Information") calls
for accumulation unit value information "for each class of accumulation units of
the registrant derived from contracts offered by means of this prospectus[.]" In
an initial registration statement such as this one, for contracts issued by a
newly registered separate account, there ordinarily would not be any
accumulation unit value information to include. However, the Separate Account
has an operational history that predates its registration, and accumulation unit
value information since Separate Account inception is available and would be
useful to prospective Participants.
Although it was not registered until 2006, the Separate Account was established
and has been used to fund group contracts since 2002. Since the time of Separate
Account inception, Horace Mann has calculated accumulation unit values for
classes of accumulation units derived from a group contract with the same charge
structure as the Contract, and has made those calculations using the same
methods it would have used if the Separate Account (and the Contract) had been
registered. In addition, Horace Mann has audited financial statements for the
Separate Account for 2004 and 2005, before the Separate Account was registered.
Horace Mann believes that the accumulation unit value information presented in
the Appendix, and the audited financial statements as well, provide valuable
data to a prospective Participant who is trying to decide whether to purchase a
Certificate and how to allocate his/her purchase payment among the investment
options available under the Contract. The language under the heading "Condensed
Financial Information" is intended to eliminate any confusion on the part of
prospective Participants by providing an accurate description of the basis for
the accumulation unit value information being presented.
If you have any questions or further comments, please call the undersigned at
217-788-5757 or Stephen E. Roth at 202.383.0158.
Very truly yours,
/s/ Ann Caparros
Ann M. Caparros
General Counsel and Corporate Secretary
Horace Mann Life Insurance Company
cc: Stephen E. Roth