The Securities and Exchange Commission has not necessarily reviewed the information in this filing and has not determined if it is accurate and complete.
The reader should not assume that the information is accurate and complete.

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM D

Notice of Exempt Offering of Securities
OMB APPROVAL
OMB Number: 3235-0076
Estimated average burden
hours per response: 4.00

1. Issuer's Identity

CIK (Filer ID Number) Previous Names
   None
Entity Type
0001167612
KILICO VARIABLE SERIES III SEPARATE ACCOUNT
KILICO Variable Series III Separate Account
   Corporation
   Limited Partnership
   Limited Liability Company
   General Partnership
   Business Trust
X Other (Specify)

Insurance Company Separate Account
Name of Issuer
ZALICO VARIABLE SERIES III SEPARATE ACCOUNT
Jurisdiction of Incorporation/Organization
ILLINOIS
Year of Incorporation/Organization
X Over Five Years Ago
   Within Last Five Years (Specify Year)
   Yet to Be Formed

2. Principal Place of Business and Contact Information

Name of Issuer
ZALICO VARIABLE SERIES III SEPARATE ACCOUNT
Street Address 1 Street Address 2
1400 AMERICAN LANE
City State/Province/Country ZIP/PostalCode Phone Number of Issuer
SCHAUMBURG ILLINOIS 60196 425-577-5100

1. Issuer's Identity

CIK (Filer ID Number) Previous Names
   None
Entity Type
0000351754
KEMPER INVESTORS LIFE INSURANCE CO
Kemper Investors Life Insurance Company
X Corporation
   Limited Partnership
   Limited Liability Company
   General Partnership
   Business Trust
   Other (Specify)

Name of Issuer
Zurich American Life Insurance Co
Jurisdiction of Incorporation/Organization
ILLINOIS
Year of Incorporation/Organization
X Over Five Years Ago
   Within Last Five Years (Specify Year)
   Yet to Be Formed

2. Principal Place of Business and Contact Information

Name of Issuer
Zurich American Life Insurance Co
Street Address 1 Street Address 2
1400 AMERICAN LANE
City State/Province/Country ZIP/PostalCode Phone Number of Issuer
SCHAUMBURG ILLINOIS 60196 425-577-5100

3. Related Persons

Last Name First Name Middle Name
Dietz David
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer X Director    Promoter

Clarification of Response (if Necessary):

President, Chief Executive Officer and Director of Zurich American Life Insurance Company
Last Name First Name Middle Name
Cummings-Fritz Dawn
Street Address 1 Street Address 2
1400 American Lane
City State/Province/Country ZIP/PostalCode
Schaumburg ILLINOIS 60196
Relationship: X Executive Officer X Director    Promoter

Clarification of Response (if Necessary):

Director and Assistant Vice President of Zurich American Life Insurance Company
Last Name First Name Middle Name
Hauser Richard
Street Address 1 Street Address 2
1400 American Lane
City State/Province/Country ZIP/PostalCode
Schaumburg ILLINOIS 60196
Relationship:    Executive Officer X Director    Promoter

Clarification of Response (if Necessary):

Director of Zurich American Life Insurance Company
Last Name First Name Middle Name
Noftke Paul
Street Address 1 Street Address 2
1400 American Lane
City State/Province/Country ZIP/PostalCode
Schaumburg ILLINOIS 60196
Relationship:    Executive Officer X Director    Promoter

Clarification of Response (if Necessary):

Director of Zurich American Life Insurance Company
Last Name First Name Middle Name
Carty Patrick
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President, General Counsel and Corporate Secretary of Zurich American Life Insurance Company
Last Name First Name Middle Name
Grilli Richard
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Senior Vice President and Chief Operating Officer of Zurich American Life Insurance Company
Last Name First Name Middle Name
Horton Jeffrey
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President, Finance and Treasurer of Zurich American Life Insurance Company
Last Name First Name Middle Name
Hall Cathy
Street Address 1 Street Address 2
3003 77th Avenue SE
City State/Province/Country ZIP/PostalCode
Mercer Island WASHINGTON 98040
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President and Chief Compliance Officer of Zurich American Life Insurance Company
Last Name First Name Middle Name
Rohwetter Michael
Street Address 1 Street Address 2
One Libert Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President and Chief Investment Officer of Zurich American Life Insurance Company
Last Name First Name Middle Name
Ehrlich Cathy
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President and Chief Actuary of Zurich American Life Insurance Company
Last Name First Name Middle Name
Roberts Dennis
Street Address 1 Street Address 2
2000 West Sam Houston Parkway
City State/Province/Country ZIP/PostalCode
Houston TEXAS 77042
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President of Zurich American Life Insurance Company
Last Name First Name Middle Name
Lodge Simon
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Senior Vice President ad Chief Financial Officer of Zurich American Life Insurance Company
Last Name First Name Middle Name
Stuart Berman
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 30th Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship:    Executive Officer X Director    Promoter

Clarification of Response (if Necessary):

Director of Zurich American Life Insurance Company
Last Name First Name Middle Name
Martin Audrey
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President, Human Resources of Zurich American Life Insurance Company
Last Name First Name Middle Name
McInerney Elizabeth
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President and Chief Operations Officer of Zurich American Life Insurance Company
Last Name First Name Middle Name
Labno Margaret
Street Address 1 Street Address 2
1400 American Lane
City State/Province/Country ZIP/PostalCode
Schaumburg ILLINOIS 60196
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Vice President of Zurich American Life Insurance Company
Last Name First Name Middle Name
Dampman David
Street Address 1 Street Address 2
7045 College Boulevard
City State/Province/Country ZIP/PostalCode
Overland Park KANSAS 66211
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Secretary of Zurich American Life Insurance Company.
Last Name First Name Middle Name
Badgett Leeann
Street Address 1 Street Address 2
3003 77th Avenue SE
City State/Province/Country ZIP/PostalCode
Mercer Island WASHINGTON 98040
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Vice President of Zurich American Life Insurance Company.
Last Name First Name Middle Name
Baltazar Lisa
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Secretary of Zurich American Life Insurance Company
Last Name First Name Middle Name
Denning Mary
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Vice President, Actuary of Zurich American Life Insurance Company
Last Name First Name Middle Name
Nagel Jon
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Secretary of Zurich American Life Insurance Company
Last Name First Name Middle Name
Broek Debra
Street Address 1 Street Address 2
1400 American Lane
City State/Province/Country ZIP/PostalCode
Schaumburg ILLINOIS 60196
Relationship:    Executive Officer X Director    Promoter

Clarification of Response (if Necessary):

Director of Zurich American Life Insurance Company
Last Name First Name Middle Name
Ehlers Eileen
Street Address 1 Street Address 2
7045 College Boulevard
City State/Province/Country ZIP/PostalCode
Overland Park KANSAS 66211
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Vice President, Underwriting of Zurich American Life Insurance Company
Last Name First Name Middle Name
Thomas Juanita
Street Address 1 Street Address 2
1114 Georgia Street
City State/Province/Country ZIP/PostalCode
Louisiana MISSOURI 63353
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Secretary of Zurich American Life Insurance Company
Last Name First Name Middle Name
Gibson Robert
Street Address 1 Street Address 2
3003 77th Ave SE
City State/Province/Country ZIP/PostalCode
Mercer Island WASHINGTON 98040
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

38a-1 Chief Compliance Officer of Zurich American Life Insurance Company
Last Name First Name Middle Name
Kleinman Ira
Street Address 1 Street Address 2
1400 American Lande
City State/Province/Country ZIP/PostalCode
Schaumburg ILLINOIS 60196
Relationship:    Executive Officer X Director    Promoter

Clarification of Response (if Necessary):

Director of Zurich American Life Insurance Company
Last Name First Name Middle Name
Patton John
Street Address 1 Street Address 2
3003 77th Ave SE
City State/Province/Country ZIP/PostalCode
Mercer Island WASHINGTON 98040
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President, Claims of Zurich American Life Insurance Company
Last Name First Name Middle Name
Pietrolugo Louis
Street Address 1 Street Address 2
1400 American Lane
City State/Province/Country ZIP/PostalCode
Schaumburg ILLINOIS 60196
Relationship:    Executive Officer X Director    Promoter

Clarification of Response (if Necessary):

Director of Zurich American Life Insurance Company
Last Name First Name Middle Name
Chandler Eric
Street Address 1 Street Address 2
3003 77th Ave SE
City State/Province/Country ZIP/PostalCode
Mercer Island WASHINGTON 98040
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Secretary of Zurich American Life Insurance Company
Last Name First Name Middle Name
Wolf Matt
Street Address 1 Street Address 2
One Liberty Plaza 165 Broadway, 21st Floor
City State/Province/Country ZIP/PostalCode
New York NEW YORK 10006
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Vice President, Actuary of Zurich American Life Insurance Company
Last Name First Name Middle Name
Miskel John
Street Address 1 Street Address 2
900 South Pine Island Road
City State/Province/Country ZIP/PostalCode
Plantation FLORIDA 33324
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President of Zurich American Life Insurance Company
Last Name First Name Middle Name
Gibbons Ryan
Street Address 1 Street Address 2
1400 American Lane
City State/Province/Country ZIP/PostalCode
Schaumburg ILLINOIS 60196
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Assistant Vice President-Tax of Zurich American Life Insurance Company
Last Name First Name Middle Name
Henderson Judith
Street Address 1 Street Address 2
3003 77th Ave SE
City State/Province/Country ZIP/PostalCode
Mercer Island WASHINGTON 98040
Relationship: X Executive Officer    Director    Promoter

Clarification of Response (if Necessary):

Vice President, IT Operations of Zurich American Life Insurance Company

4. Industry Group

   Agriculture
Banking & Financial Services
   Commercial Banking
X Insurance
   Investing
   Investment Banking
   Pooled Investment Fund
Is the issuer registered as
an investment company under
the Investment Company
Act of 1940?
   Yes    No
   Other Banking & Financial Services
   Business Services
Energy
   Coal Mining
   Electric Utilities
   Energy Conservation
   Environmental Services
   Oil & Gas
   Other Energy
Health Care
   Biotechnology
   Health Insurance
   Hospitals & Physicians
   Pharmaceuticals
   Other Health Care
   Manufacturing
Real Estate
   Commercial
   Construction
   REITS & Finance
   Residential
   Other Real Estate
  
 Retailing
  
 Restaurants
Technology
   Computers
   Telecommunications
   Other Technology
Travel
   Airlines & Airports
   Lodging & Conventions
   Tourism & Travel Services
   Other Travel
  
 Other

5. Issuer Size

Revenue Range OR Aggregate Net Asset Value Range
   No Revenues    No Aggregate Net Asset Value
   $1 - $1,000,000    $1 - $5,000,000
   $1,000,001 - $5,000,000    $5,000,001 - $25,000,000
   $5,000,001 - $25,000,000    $25,000,001 - $50,000,000
   $25,000,001 - $100,000,000    $50,000,001 - $100,000,000
   Over $100,000,000    Over $100,000,000
X Decline to Disclose    Decline to Disclose
   Not Applicable    Not Applicable

6. Federal Exemption(s) and Exclusion(s) Claimed (select all that apply)

   Rule 504(b)(1) (not (i), (ii) or (iii))
   Rule 504 (b)(1)(i)
   Rule 504 (b)(1)(ii)
   Rule 504 (b)(1)(iii)
   Rule 505
   Rule 506(b)
X Rule 506(c)
   Securities Act Section 4(a)(5)
X Investment Company Act Section 3(c)
   Section 3(c)(1)    Section 3(c)(9)  
   Section 3(c)(2)    Section 3(c)(10)
   Section 3(c)(3)    Section 3(c)(11)
   Section 3(c)(4)    Section 3(c)(12)
   Section 3(c)(5)    Section 3(c)(13)
   Section 3(c)(6)    Section 3(c)(14)
X Section 3(c)(7)

7. Type of Filing

   New Notice Date of First Sale 1997-09-25    First Sale Yet to Occur
X Amendment

8. Duration of Offering

Does the Issuer intend this offering to last more than one year?
X Yes    No

9. Type(s) of Securities Offered (select all that apply)

   Equity    Pooled Investment Fund Interests
   Debt    Tenant-in-Common Securities
   Option, Warrant or Other Right to Acquire Another Security    Mineral Property Securities
   Security to be Acquired Upon Exercise of Option, Warrant or Other Right to Acquire Security X Other (describe)
Interests in ZALICO Variable Series III Separate Account pursuant to Series IV survivorship variable life insurance policies

10. Business Combination Transaction

Is this offering being made in connection with a business combination transaction, such as a merger, acquisition or exchange offer?
   Yes X No

Clarification of Response (if Necessary):

11. Minimum Investment

Minimum investment accepted from any outside investor $10,000 USD

12. Sales Compensation

Recipient
Recipient CRD Number    None
Wells Fargo Insurance Services Investment Advisors, Inc. 35419
(Associated) Broker or Dealer X None
(Associated) Broker or Dealer CRD Number X None
None None
Street Address 1 Street Address 2
301 South College Street 19th Floor, Mail Code: D1053-190
City State/Province/Country ZIP/Postal Code
Charlotte NORTH CAROLINA 28202
State(s) of Solicitation (select all that apply)
Check “All States” or check individual States		    All States
   Foreign/non-US
DELAWARE
MISSOURI
Recipient
Recipient CRD Number    None
Benefit Finance Securities 45113
(Associated) Broker or Dealer X None
(Associated) Broker or Dealer CRD Number X None
None None
Street Address 1 Street Address 2
6 City Place Drive, Suite 400
City State/Province/Country ZIP/Postal Code
St. Louis MISSOURI 63141
State(s) of Solicitation (select all that apply)
Check “All States” or check individual States		    All States
   Foreign/non-US
DELAWARE
MISSOURI

13. Offering and Sales Amounts

Total Offering Amount USD
or X Indefinite
Total Amount Sold $2,549,522 USD
Total Remaining to be Sold USD
or X Indefinite

Clarification of Response (if Necessary):

14. Investors

  
 Select if securities in the offering have been or may be sold to persons who do not qualify as accredited investors, and enter the number of such non-accredited investors who already have invested in the offering.
Regardless of whether securities in the offering have been or may be sold to persons who do not qualify as accredited investors, enter the total number of investors who already have invested in the offering:
3

15. Sales Commissions & Finder's Fees Expenses

Provide separately the amounts of sales commissions and finders fees expenses, if any. If the amount of an expenditure is not known, provide an estimate and check the box next to the amount.

Sales Commissions $98,532 USD
   Estimate
Finders' Fees $0 USD
   Estimate

Clarification of Response (if Necessary):

16. Use of Proceeds

Provide the amount of the gross proceeds of the offering that has been or is proposed to be used for payments to any of the persons required to be named as executive officers, directors or promoters in response to Item 3 above. If the amount is unknown, provide an estimate and check the box next to the amount.

$0 USD
   Estimate

Clarification of Response (if Necessary):

As issuer of the variable life insurance policies, Zurich American Life Insurance Company will receive amounts from charges deducted under the policies, but no executive officer, director or promoter will receive any portion of the gross offering proceeds

Signature and Submission

Please verify the information you have entered and review the Terms of Submission below before signing and clicking SUBMIT below to file this notice.

Terms of Submission

In submitting this notice, each issuer named above is:
  • Notifying the SEC and/or each State in which this notice is filed of the offering of securities described and undertaking to furnish them, upon written request, in the accordance with applicable law, the information furnished to offerees.*
  • Irrevocably appointing each of the Secretary of the SEC and, the Securities Administrator or other legally designated officer of the State in which the issuer maintains its principal place of business and any State in which this notice is filed, as its agents for service of process, and agreeing that these persons may accept service on its behalf, of any notice, process or pleading, and further agreeing that such service may be made by registered or certified mail, in any Federal or state action, administrative proceeding, or arbitration brought against the issuer in any place subject to the jurisdiction of the United States, if the action, proceeding or arbitration (a) arises out of any activity in connection with the offering of securities that is the subject of this notice, and (b) is founded, directly or indirectly, upon the provisions of:  (i) the Securities Act of 1933, the Securities Exchange Act of 1934, the Trust Indenture Act of 1939, the Investment Company Act of 1940, or the Investment Advisers Act of 1940, or any rule or regulation under any of these statutes, or (ii) the laws of the State in which the issuer maintains its principal place of business or any State in which this notice is filed.
  • Certifying that, if the issuer is claiming a Regulation D exemption for the offering, the issuer is not disqualified from relying on Regulation D for one of the reasons stated in Rule 505(b)(2)(iii) or Rule 506(d).

Each Issuer identified above has read this notice, knows the contents to be true, and has duly caused this notice to be signed on its behalf by the undersigned duly authorized person.

For signature, type in the signer's name or other letters or characters adopted or authorized as the signer's signature.

X I also am a duly authorized representative of the other issuer(s) identified in Item 1 above and authorized to sign on their behalf.
Issuer Signature Name of Signer Title Date
ZALICO VARIABLE SERIES III SEPARATE ACCOUNT Richard W. Grilli- Richard W. Grilli Chief Operating Officer and Senior Vice President 2016-11-17

Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB number.

* This undertaking does not affect any limits Section 102(a) of the National Securities Markets Improvement Act of 1996 ("NSMIA") [Pub. L. No. 104-290, 110 Stat. 3416 (Oct. 11, 1996)] imposes on the ability of States to require information. As a result, if the securities that are the subject of this Form D are "covered securities" for purposes of NSMIA, whether in all instances or due to the nature of the offering that is the subject of this Form D, States cannot routinely require offering materials under this undertaking or otherwise and can require offering materials only to the extent NSMIA permits them to do so under NSMIA's preservation of their anti-fraud authority.