-----BEGIN PRIVACY-ENHANCED MESSAGE----- Proc-Type: 2001,MIC-CLEAR Originator-Name: webmaster@www.sec.gov Originator-Key-Asymmetric: MFgwCgYEVQgBAQICAf8DSgAwRwJAW2sNKK9AVtBzYZmr6aGjlWyK3XmZv3dTINen TWSM7vrzLADbmYQaionwg5sDW3P6oaM5D3tdezXMm7z1T+B+twIDAQAB MIC-Info: RSA-MD5,RSA, ArOe6QjNTnwGh5EEdIPdGDzAQ2IjNOGoZNJ4+fzoISSswn4RnAHQvNm9Rl9+NivK dLm9nZdltwW66BejwcyeCQ== 0001104659-10-062122.txt : 20110203 0001104659-10-062122.hdr.sgml : 20110203 20101210141425 ACCESSION NUMBER: 0001104659-10-062122 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20101210 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SEPARATE ACCOUNT I OF INTEGRITY LIFE INSURANCE CO CENTRAL INDEX KEY: 0000802205 IRS NUMBER: 000000000 STATE OF INCORPORATION: OH FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 515 WEST MARKET ST STREET 2: 7TH FLOOR CITY: LOUISVILLE STATE: KY ZIP: 40202 BUSINESS PHONE: 5025827900 MAIL ADDRESS: STREET 1: 515 WEST MARKET ST STREET 2: 7TH FLOOR CITY: LOUISVILLE STATE: KY ZIP: 40202 FORMER COMPANY: FORMER CONFORMED NAME: SEPARATE ACCOUNT INA OF INTEGRITY LIFE INSURANCE CO DATE OF NAME CHANGE: 19920703 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SEPARATE ACCOUNT I OF NATIONAL INTEGRITY LIFE INS CO CENTRAL INDEX KEY: 0000802222 IRS NUMBER: 000000000 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 515 WEST MARKET STREET CITY: LOUISVILLE STATE: KY ZIP: 40202 BUSINESS PHONE: 5025827900 MAIL ADDRESS: STREET 1: 515 WEST MARKET STREET CITY: LOUISVILLE STATE: KY ZIP: 40202 FORMER COMPANY: FORMER CONFORMED NAME: SEPARATE ACCOUNT NIA OF NATIONAL INTEGRITY LIFE INS CO DATE OF NAME CHANGE: 19920703 CORRESP 1 filename1.htm

 

Western & Southern Financial Group, Inc.

400 Broadway

Cincinnati, OH 45202

 

Via electronic mail

 

December 1, 2010

 

Ms. Alison White

Senior Counsel, Office of Insurance Products

Division of Investment Management

Securities and Exchange Commission

100 F. Street N.E.

Washington, D.C. 20549

 

RE:         Integrity Life Insurance Company (“Integrity”)

Separate Account I of Integrity Life Insurance Company

File Numbers 333-166995 and 811-04844

 

National Integrity Life Insurance Company (“National Integrity”)

Separate Account I of National Integrity Life Insurance Company

File Numbers 333-167372 and 811-04846

 

Dear Ms. White:

 

This letter is in response to questions from you and Ms. Pickholz received via phone yesterday, November 30, 2010.  The questions are restated below and each one has been addressed.

 

Please recall that Integrity is making a commitment to give owners a unit value based on the market at close price of the underlying ETFs. Integrity has entered into an agreement with MATC to provide the ETF shares to the separate account on that basis. We respectfully note that the answers to the questions raised do not affect in any way our obligation to meet the terms of our contract as described in the prospectus.  In light of the foregoing, following are answers to your questions:

 

1.     Will the purchases and sales by the executing brokers of the ETFs held in the subaccount be effected on a principal or agency basis?

 

Trades may be effected on either an agency or a principal basis, depending on the executing broker’s book, market outlook, hedging requirements, and other considerations.  In either case, the subaccount will receive the same execution price, as the price is determined by the market closing price on the primary exchange.

 

2.     Are the executing brokers “authorized participants” for purposes of the construction of ETF creation units?

 


 

Typically, yes, although coverage of specific ETFs may vary by executing broker.  We believe this is beneficial, as it provides the executing brokers with another possible avenue for filling orders.  Please note, however, that the requirement is to honor the market closing price on the primary exchange, and this is not dependent on the executing brokers being an “authorized participant” of the ETF being traded.

 

In connection with the foregoing we acknowledge that: (i) Integrity and National Integrity are responsible for the adequacy and accuracy of the disclosure in the Registration Statements; (ii) the comments of the Commission’s Staff, or changes to disclosures in the Registration Statements in response to the comments of the Commission’s Staff, does not foreclose the Commission from taking any action with respect to the Registration Statements; and (iii) neither Integrity nor National Integrity may assert the comments of the Commission’s Staff as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 

 

Sincerely,

 

 

 

 

 

/s/ Kevin L. Howard

 

Vice President and Associate General Counsel

 

Western & Southern Financial Group, Inc.

 

Copy:     Michael Berenson, Esq. via electronic mail

Rhonda S. Malone, Esq. via electronic mail

 

 

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