Correspondence Filing Via EDGAR

December 12, 2011

Ms. Sally Samuel

Senior Counsel, Office of Insurance Products

Division of Investment Management

Securities and Exchange Commission

100 F. Street N.E.

Washington, D.C. 20549

RE:	Separate Account I of Integrity Life Insurance Company
	Response to SEC comments on Initial Registration Statement on Form N-4
	File Numbers 333-177617 and 811-04844

Dear Ms. Samuel:

This letter is in response to the comments of the Securities and Exchange Commission (Commission) staff (Staff) received via phone on November 30, 2011 and December 1, 2011 on the above-referenced registration statement. This registration statement was filed in connection with a request for no-action relief initially submitted June 28, 2011 by Integrity Life Insurance Company (“Company”), National Integrity Life Insurance Company and Western-Southern Life Assurance Company, revised most recently on December 6, 2011, related to the consolidation by each insurance company of its two separate accounts.

The Staff’s comments are incorporated in the revised prospectus attached hereto as Exhibit A. The changes requested are redlined for your convenience.

We plan to file a pre-effective amendment to the registration statement on December 28, 2011. In order to get the consents from our independent auditor in a cost effective manner, we have coordinated the timing of their review of the financial statements with the reviews and consents being provided in connection with five other filings related to this consolidation of separate accounts project. The auditor consent process is the most expensive element involved in filing any registration statement or amendment; therefore, coordinating these consents is a critical cost savings measure. With this explanation in mind, we hope you will accept this correspondence and exhibits, as well as our commitments herein, as a complete response to your comments.

We respectfully request your assurance that if the pre-effective amendment filed on December 28, 2011 meets all criteria set forth in this letter, addresses any additional comments the Staff may have and is otherwise correct and complete, you will accelerate the registration statement making it effective by December 30, 2011. We greatly appreciate your cooperation in this regard.

In connection with the foregoing, registrant acknowledges that: (i) should the Commission or the Staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filings; (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the registrant from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and (iii) the registrant may not assert this action as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

If you have any questions or need additional information, please do not hesitate to call me at 513-629-1854.

	Sincerely,
	\s\ Rhonda S. Malone
	Counsel — Securities
	Western & Southern Financial Group, Inc.

Select Ten Plus

Integrity Life Insurance Company

Separate Account I of Integrity Life Insurance Company

December 30, 2011

This prospectus describes the Select Ten Plus flexible premium variable annuity contract and the Investment Options available under the contract. This prospectus contains information about Separate Account I of Integrity Life Insurance Company (Separate Account I) and the contract that you should know before investing. You should read this prospectus and any supplements, and retain them for future reference.

The Securities and Exchange Commission (SEC) has not approved or disapproved these securities or determined that this prospectus is adequate. Any representation to the contrary is a criminal offense.

A registration statement relating to this contract, which includes a Statement of Additional Information (SAI) dated December 30, 2011, material incorporated by reference and other information about Separate Account I and Integrity Life Insurance Company, has been filed with the Securities and Exchange Commission (file numbers 811-04844 and 333-177617.) The SAI is incorporated by reference into this prospectus. A free copy of the SAI is available by sending in the form at the bottom of this page, or by writing or calling our Administrative Office listed in the Glossary. The table of contents for the SAI is found in Part 8 of this prospectus.

You can review and copy information about this annuity contract at the SEC’s Public Reference Room in Washington, D.C. For hours of operation of the Public Reference Room, please call 202-551-8090. You may also obtain information about this annuity contract on the SEC’s Internet site at http://www.sec.gov. Copies of that information are also available, after paying a duplicating fee, by writing the SEC’s Public Reference Section, 100 F. Street NE, Washington, D.C. 20459-0102.

This prospectus does not constitute an offering in any jurisdiction in which such offering may not lawfully be made. No person is authorized to make any representations in connection with this offering other than those contained in this prospectus.

You may invest your contributions in:

Touchstone Variable Series Trust - Touchstone VST Large Cap Core Equity Fund

This annuity is not a bank product and is not an obligation of, nor guaranteed by, the financial institution where it is offered. It is not insured by the FDIC, NCUSIF or other federal entity. It is subject to investment risks, including possible loss of the principal amount invested.

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TABLE OF CONTENTS

[PAGE NUMBERS WILL BE UPDATED IN FINAL PRE-EFFECTIVE AMENDMENT FILING]

		Page STP-
Glossary		4
Part 1 — Fees and Expense Tables and Summary		5
Annual Administrative Charge		5
Separate Account Annual Expenses		5
Total Annual Portfolio Operating Expenses		5
Examples		5
Accumulation Unit Values		5
Summary of Contract		6
Investment Goals and Risks		6
Your Rights and Benefits		6
Account Value and Surrender Value		6
Your Right to Revoke (Free Look Period)		7
How Your Contract is Taxed		7
Part 2 - Integrity and the Separate Account		7
Integrity Life Insurance Company		7
Separate Account I and the Variable Account Options		7
Distribution of Variable Annuity Contracts		8
Changes In How We Operate		8
Part 3 - Your Investment Option		8
The Variable Account Option		8
Part 4 - Deductions and Charges		9
Mortality and Expense Risk Charge		9
Annual Administrative Charge		9
Reduction of the Mortality and Expense Risk Charge or Annual Administrative Charge		9
Portfolio Charges		9
Payments to Distributors		9
Tax Reserve		10
State Premium Tax		10
Part 5 - Terms of Your Variable Annuity		10
Your Contributions		10
Units in Our Separate Account		10
How We Determine Unit Value		11
Withdrawals		11
Assignments		11
Death Benefit Paid on Death of Annuitant		12
Distribution on Death of Owner		13
Spousal Continuation		14
Death Claims		14
Retirement Date and Annuity Benefit		14
Annuity Benefit Payments		15
Timing of Payment		15
How You Make Requests and Give Instructions		16
Part 6 - Voting Rights		16
How Portfolio Shares Are Voted		16
How We Determine Your Voting Shares		16
Part 7 - Tax Aspects of the Contract		17
Introduction		17
Your Contract is an Annuity		17
Taxation of Annuities Generally		17
Tax-Favored Retirement Programs		18

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Federal and State Income Tax Withholding		19
Impact of Taxes on the Company		19
Part 8 - Additional Information		20
Systematic Withdrawal Program		20
Income Plus Withdrawal Program		20
Choices Plus Required Minimum Distribution Program		20
Legal Proceedings		21
Table of Contents of Statement of Additional Information		21

Appendix A - Financial Information for Separate Account I		22

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GLOSSARY

Account Value - the value of your contract.

Administrative Office - Integrity Life Insurance Company, P.O. Box 5720, 400 Broadway, Cincinnati, Ohio 45201-5720. You may also call us at 1-800-325-8583.

Annuitant - the person whose life is used to determine the Maximum Retirement Date and the amount of the Annuity Benefit and whose death triggers the payment of the Death Benefit. The Annuitant must be a natural person, and cannot be changed after the Contract Date.

Annuity Benefit — periodic payments beginning on your Retirement Date.

Business Day - any day that the New York Stock Exchange is open.

Contract Date - the date we issue you the contract. It is shown on the schedule page of your contract.

Contract Year - a year that starts on your Contract Date or any anniversary of the Contract Date.

Death Benefit - benefit paid to a named Annuitant’s beneficiary on the death of the Annuitant.

Distribution on Death — a distribution paid to a named owner’s beneficiary on the death of the owner.

General Account - the account that contains all of our assets other than those held in Separate Accounts.

Portfolio - a mutual fund in which a Variable Account Option invests.

Retirement Date - the date you choose to begin your Annuity Benefit.

Separate Account - Separate Account I of Integrity Life Insurance Company.

Surrender Value - your Account Value reduced by any pro rata annual administrative charges and optional benefit charges. Also called Cash Value.

Unit - measure of your ownership interest in a Variable Account Option.

Unit Value - value of each Unit calculated on any Business Day.

Variable Account Option — the Investment Option available to you under the contract. The Variable Account Option invests in a corresponding Portfolio with the same name.

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Part 1 — Fees and Expense Tables and Summary

The following tables describe the fees and expenses that you will pay when buying, owning, withdrawing from and surrendering the contract. State premium tax may also be deducted.(1)

The following tables describe the fees and expenses that you will pay periodically during the time that you own the contract, not including Total Annual Portfolio (a mutual fund in which a Variable Account Option invests) Operating Expenses.

Annual Administrative Charge

Annual Administrative Charge(2)

Separate Account Annual Expenses as a percentage of average account value

Mortality and Expense Risk Charge

1.35

The following table shows the total operating expenses charged by the Portfolio that you will pay periodically during the time you own the contract. More detail concerning each Portfolio’s fees and expenses is contained in the prospectus for each Portfolio.

Total Annual Portfolio Operating Expenses

Touchstone VST Large Cap Core Equity Fund

1.04

Examples

The examples that follow are intended to help you compare the cost of investing in this contract with the cost of investing in other variable annuity contracts. Each example assumes that you invest $10,000 in the contract for the time period indicated. Each example also assumes that your investment has a 5% return each year. Your actual costs may be higher or lower.

The following example includes the annual administrative charge, the mortality and expense risk charge, and maximum Portfolio operating expenses. Based on these assumptions, your costs would be:

If you surrender your contract at the end of the applicable period:

1 year		3 years		5 years		10 years
$	279	$	855	$	1,454	$	3,060

If you keep your contract in force or select an Annuity Benefit (periodic payments beginning on the date you choose) with a life contingency at the end of the applicable period:

1 year		3 years		5 years		10 years
$	279	$	855	$	1,454	$	3,060

Accumulation Unit Values

See Appendix A

(1) State premium taxes currently range from 0 to 3.5%.

(2) This charge will be waived if the Account Value is at least $50,000 on the last day of the Contract Year.

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Summary of Contract

“We,” “our,” “us,” “the Company” and “Integrity” mean Integrity Life Insurance Company. “You” and “your” mean the owner. This variable annuity contract is a contract between you and us. You, as the owner, have certain rights under the contract. The Annuitant (the person whose life is used to determine the Maximum Retirement Date, which is the date you choose to begin your Annuity Benefit, and the amount of the Annuity Benefit and whose death triggers the payment of the Death Benefit) named by you may be you or another person. It is important that you carefully select the owner, Annuitant, the owner’s beneficiary and the Annuitant’s beneficiary in order to achieve your objectives. See Part 5, sections titled “Death Benefits Paid on Death of Annuitant” and “Distribution on Death of Owner.”

Investment Goals and Risks

This contract allows you to accumulate money for retirement or other long term goals. An investment in the Variable Account Option (the Investment Option available to you under the contract that invests in a corresponding Portfolio with the same name) carries with it certain risks, including the risk that the value of your investment will decline and you could lose money. The Variable Account Option invests in a Portfolio, which invests in common stocks. You could lose money if one of the issuers of the stocks in which your Variable Account Option invests through its underlying Portfolio becomes financially impaired or if the stock market as a whole declines. There’s also the inherent risk that holders of common stock generally are behind creditors and holders of preferred stock for payments in the event of the bankruptcy of a stock issuer.

For a complete discussion of the risks associated with investing in the Variable Account Option, see the prospectus of the corresponding Portfolio.

Your Rights and Benefits

As the owner of the contract, you have the following rights:

· To contribute and withdraw money. See Part 5

· To invest in the Investment Option. See Part 3

· To elect an Annuity Benefit. See Part 5, section titled “Retirement Date and Annuity Benefit.”

· To name the Annuitant.

· To name the Annuitant’s beneficiary. The Annuitant’s beneficiary will receive the Death Benefit upon the death of the Annuitant if the Annuitant dies before the owner. See Part 5, section titled “Death Benefit Paid on Death of Annuitant.”

· To name the owner’s beneficiary. The owner’s beneficiary will receive a distribution upon your death, as owner, if you die before the Annuitant. If there are joint owners, the death of either one will be treated as the death of both under this contract. The death of either owner triggers a required Distribution on Death (a distribution paid to a named owner’s beneficiary on the death of the owner). See Part 5, section titled “Distribution on Death of Owner.”

Account Value and Surrender Value

Your Account Value consists of the value of your Investment Option. Any amount allocated to the Variable Account Option will go up or down in value depending on the investment experience of that corresponding Portfolio. The value of contributions allocated to the Variable Account Options is not guaranteed. Your Account Value is subject to various charges. See Part 4.

Your Surrender Value (or “Cash Value”) is equal to your Account Value minus the pro rata portion of the annual administrative charges. See Part 4.

Your minimum Account Value is $1,000. If the Account Value goes below $1,000 and we have received no contributions from you for two years, we reserve the right to terminate the contract and pay you the Account Value. We will notify you in advance and will give you at least 60 days to make additional contributions.

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Your Right to Revoke (Free Look Period)

You may cancel your contract within ten days after you receive it by returning it to our Administrative Office (Integrity Life Insurance Company, P.O. Box 5720, 400 Broadway, Cincinnati, Ohio 45201-5720). We will extend the ten day period if required by state law. If you cancel your contract, we’ll return your contribution net of any investment performance and applicable charges, which may be more or less than your original contribution depending upon the investment experience of the Investment Option. You bear the investment risk during the ten-day period, as well as any fees and charges incurred during the period your contract is in force. See Part 4.

How Your Contract is Taxed

Your benefits under the contract are controlled by the Internal Revenue Code of 1986, as amended (the Code) and the associated rules and regulations governing annuities, including the deferral of taxes on your investment growth until you actually make a withdrawal. You should read Part 7, “Tax Aspects of the Contract” for more information, and consult a tax advisor. Most of the withdrawals you make before you are 59½ years old are subject to a 10% federal tax penalty on the taxable portion of the amounts withdrawn. This contract can provide benefits under certain tax-favored retirement programs, such as IRAs; however, it provides no additional tax deferral benefit, as these programs already provide tax-deferral.

Part 2 — Integrity and the Separate Account

Integrity Life Insurance Company

Integrity is a stock life insurance company organized under the laws of Arizona on May 3, 1966, and redomesticated to Ohio on January 3, 1995. Our principal executive office is located at 400 Broadway, Cincinnati, Ohio 45202. We are authorized to sell life insurance and annuities in 46 states and the District of Columbia. Integrity is a subsidiary of The Western and Southern Life Insurance Company, a life insurance company organized under the laws of the State of Ohio on February 23, 1888. The Western and Southern Life Insurance Company has guaranteed the insurance obligations of Integrity to its contract owners, including the owners of this contract (the Guarantee). Insurance obligations include the Death Benefit (benefit paid to a named Annuitant’s beneficiary on the death of the Annuitant) and Annuity Benefit. The Guarantee does not guarantee investment performance of the Variable Account Option. The Guarantee provides that contract owners can enforce the Guarantee directly.

Separate Account I and the Variable Account Option

Separate Account I was established in 1986, and is maintained under the insurance laws of the State of Ohio. The Separate Account is a unit investment trust, which is a type of investment company governed by the 1940 Act.

Under Ohio law, we own the assets of our Separate Account and use them to support the Variable Account Options of your contract and other variable annuity contracts. You participate in the Separate Account in proportion to the amounts in your Variable Account Options. Integrity Life Insurance Company is responsible for all obligations under the contract.

Income, gains and losses, whether realized or unrealized, from assets allocated to the Separate Account are credited to or charged against the Separate Account without regard to our other income, gains or losses. The assets of the Separate Account may not be charged with the liabilities arising out of our other businesses. We may allow fees that are owed to us to stay in the Separate Account, and, in that way, we can participate proportionately in the Separate Account. We may also periodically withdraw amounts that are earned and owed to us from the Separate Account.

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Distribution of Variable Annuity Contracts

Touchstone Securities, Inc., an affiliate of Integrity, serves as the principal underwriter for our variable annuity contracts. The principal business address of Touchstone Securities is 303 Broadway, Cincinnati, Ohio, 45202. The contracts are sold by individuals who represent us as insurance agents and who are also registered representatives of broker-dealers or financial institutions that have entered into distribution agreements with us.

Changes in How We Operate

We can change how the Company or our Separate Account operates, subject to your approval when required by the 1940 Act or other applicable laws. We’ll notify you if any changes result in a material change in the underlying investments of a Variable Account Option. We may:

· add, remove or combine Investment Options or withdraw assets relating to your contract from one Variable Account Option and put them into another;

· register or end the registration of the Separate Account under the 1940 Act;

· operate our Separate Account under the direction of a committee or discharge a committee at any time (the committee may be composed of a majority of persons who are “interested persons” of Integrity);

· restrict or eliminate any voting rights of owners or others that affect our Separate Account; this may only arise if there is a change in current SEC rules;

· cause one or more Variable Account Options to invest in a Portfolio other than or in addition to the Portfolios; or

· operate our Separate Account or one or more of the Investment Options in any other form the law allows, including a form that allows us to make direct investments.

Section 3 - Your Investment Option

The Variable Account Option

The Variable Account Option invests in the Portfolio (or “Fund”) with the corresponding name. The investment objective, advisor and subadvisor, if any, of each Portfolio are described below. Management fees and other expenses deducted from each Portfolio are described in that Portfolio’s prospectus. For a prospectus containing more complete information on any Portfolio, call our Administrative Office toll-free at 1-800-325-8583.

Touchstone® Variable Series Trust

The Portfolio offered is a series of the Touchstone Variable Series Trust. The advisor of the fund is Touchstone Advisors, Inc., located at 303 Broadway, Suite 1100, Cincinnati, Ohio 45202, which is affiliated with us. The sub-advisor is Todd/Veredus Asset Management LLC, located at 101 South Fifth Street, Suite 3160, Louisville, KY 40202.

Below is a brief description of the Portfolio. There are no guarantees that a fund will achieve its objective. You should read the Touchstone VST fund’s prospectus carefully before investing.

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Touchstone VST Large Cap Core Equity Fund

The Touchstone VST Large Cap Core Equity Fund seeks long-term capital appreciation as its primary goal and income as its secondary goal. The sub-advisor invests at least 80% of the fund’s assets in common stocks of companies with market capitalizations in the range of the Russell 1000 Index. The sub-advisor selects stocks that it believes are attractively valued with active catalysts in place.

Section 4 - Deductions and Charges

Mortality and Expense Risk Charge

We deduct a daily charge equal to an annual effective rate of 1.35% of your Account Value in each of the Variable Account Options to cover mortality and expense risk and certain administrative expenses. A portion of the 1.35% pays us for assuming the mortality risk and the expense risk under the contract. The mortality risk, as used here, refers to the risk we take that annuitants, as a class of persons, will live longer than estimated and we will be required to pay out more Annuity Benefits or greater Death Benefits than anticipated. The expense risk is the risk that the actual expenses of administering and distributing the contract will exceed the reimbursement for administrative expenses. A portion of the 1.35% is used to reimburse us for administrative expenses not covered by the annual administrative charge described below, including the cost of distribution of the contracts. We expect to make a profit from this fee. The mortality and expense risk charge can’t be increased without your consent.

Annual Administrative Charge

We charge an annual administrative charge of $30, which is deducted on the last day of the Contract Year (a year that starts on your Contract Date or any anniversary of the Contract Date) if your Account Value is less than $50,000 on that day. This charge is taken pro rata from your Account Value in each Investment Option. The charge reduces the number of Units (a Unit is a measure of your ownership interest in a Variable Account Option) we credit to you. The annual administrative charge is pro-rated if you surrender the contract, select an Annuity Benefit, or if Death Benefits are calculated during a Contract Year.

Portfolio Charges

The Separate Account buys shares of the Portfolio at net asset value. That price reflects investment management fees and other direct expenses that have already been deducted from the assets of the Portfolio. The amount charged for investment management can’t be increased without shareholder approval. Please refer to the Portfolio prospectuses for complete details on Portfolio expenses and related items.

Payments to Distributors

We generally pay a commission to the sales representative. Commissions vary due to differences among states, sales channels, sales firms and special sales initiatives.

A broker-dealer or financial institution that distributes our variable annuity contracts may receive additional compensation from us for training, marketing or other services provided. In addition to commissions, we may pay additional promotional incentives, in the form of cash or other compensation. We may also pay a broker-dealer additional fees to ensure that firm’s registered representatives have access, or preferred access, to our products.

Depending on the arrangements in place at any particular time, a broker-dealer, and the registered representatives associated with it, may have a financial incentive to recommend a particular variable annuity contract. This could be considered a conflict of interest.

Integrity has agreements with the following broker-dealer firms under which we pay varying amounts on

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contributions paid, but no more than 0.25%, for enhanced access to their registered representatives. The broker-dealer firms are American Portfolios Financial Services, Inc., BB&T Investment Services, Inc., Cadaret, Grant & Co., Inc., Comerica Securities, Inc., Cuso Financial Services, L.P., Fifth Third Securities, Inc., Frost Brokerage Services, Inc., Hancock Investment Services, Inc., LPL Financial Corporation, M&T Securities, Inc., Nationwide Planning Associates, Inc., Raymond James Financial, Inc., and Stifel, Nicolaus and Company, Incorporated. .

Tax Reserve

We can make a charge in the future for taxes or for reserves set aside for taxes, which will reduce the investment performance of the Variable Account Options.

State Premium Tax

We won’t deduct state premium taxes from your contributions before investing them in the Investment Options, unless required by your state law. If you elect an Annuity Benefit, we’ll deduct any applicable state premium taxes from the amount available for the Annuity Benefit. State premium taxes currently range from 0 to 3.5%.

Section 5 - Terms of Your Variable Annuity

Your Contributions

You can make contributions of at least $100 at any time up to the Retirement Date. Your first contribution, however, can’t be less than $1,000.

We may limit the total contributions under a contract to $1,000,000 if the Annuitant is age 75 or under or to $500,000 if the Annuitant is age 76 or older. Once you reach nine years before your Retirement Date, we may refuse to accept any contribution. Contributions may also be limited by various laws or prohibited by us for all owners under the contract. If your contract is an individual retirement account (IRA), we will measure your contributions against the maximum limits for annual contributions set by federal law.

Contributions are applied to your Investment Options and are used to pay Annuity Benefits and Death Benefits. Each contribution is credited as of the date we have received (as defined below) both the contribution and instructions for allocation among the Investment Options at our Administrative Office. Wire transfers of federal funds are deemed received on the day of transmittal if credited to our account by 3 p.m. Eastern Time, otherwise they are deemed received on the next Business Day (any day that the New York Stock Exchange is open). We do not waive this policy for particular investors or classes of investors. Contributions by check sent through the mail are deemed received when they are delivered in good order to our Administrative Office.

Units in Our Separate Account

Allocations to the Variable Account Option are used to purchase Units. On any given day, the value you have in the Variable Account Option is the Unit Value (value of each Unit calculated on any Business Day) multiplied by the number of Units credited to you in that Variable Account Option.

The number of Units purchased or redeemed (sold) in a Variable Account Option is calculated by dividing the dollar amount of the transaction by the Variable Account Option’s Unit Value, calculated as of the next close of business of the New York Stock Exchange. The number of Units for a Variable Account Option at any time is the number of Units purchased less the number of Units redeemed. The value of Units fluctuates with the investment performance of the corresponding Portfolio, which in turn reflects the investment income and realized and unrealized capital gains and losses of the Portfolio, as well as the Portfolio’s expenses.

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The Unit Values also change because of deductions and charges we make to our Separate Account. The number of Units credited to you, however, won’t vary due to changes in Unit Values. Units of a Variable Account Option are purchased when you make new contributions. Units are redeemed when you make withdrawals. We also redeem Units to pay the Death Benefit when the Annuitant dies, and to pay the annual administrative charge.

How We Determine Unit Value

We determine Unit Values for each Variable Account Option at the close of business of the New York Stock Exchange, which is normally 4 p.m. Eastern Time on each Business Day. The Unit Value of a Variable Account Option for any Business Day is equal to the Unit Value for the previous Business Day, multiplied by the net investment factor for that Variable Account Option on the current day. We determine a net investment factor for each Variable Account Option as follows:

· First, we take the value of the shares belonging to the Variable Account Option in the corresponding Portfolio at the close of business that day (before giving effect to any transactions for that day, such as contributions or withdrawals). For this purpose, we use the share value reported to us by the Portfolio.

· Next, we add any dividends or capital gains distributions by the Portfolio on that day.

· Then we charge or credit for any taxes or amounts set aside as a reserve for taxes.

· Then we divide this amount by the value of the amounts in the Variable Account Option at the close of business on the last day that a Unit Value was determined (after giving effect to any transactions on that day).

· Finally, we subtract a daily asset charge for each calendar day since the last day that a Unit Value was determined (for example, a Monday calculation will include charges for Saturday and Sunday). The daily charge is an amount equal to an annual effective rate of 1.35%. This charge is for the mortality risk, administrative expenses and expense risk we assume under the contract.

Generally, this means that we adjust Unit Values to reflect what happens to the Portfolio and for the Mortality, Expense Risk and Administrative Fees and any charge for taxes.

Withdrawals

You may make withdrawals as often as you wish. Each non systematic withdrawal must be for at least $300. No withdrawal charges apply to this contract. When you make a partial withdrawal, the total amount deducted from your Account Value will include the withdrawal amount requested. The total amount that you receive will be the total amount that you requested, less any applicable tax withholding. Most of the withdrawals you make before you are 59½ years old are subject to a 10% federal tax penalty. If your contract is part of a tax-favored plan, the plan may limit your withdrawals. See Part 7.

Your financial professional or a third party may offer you asset allocation or investment advisory services for your contract. Fees you pay for such investment advisory services are in addition to any contract charges. If you want to pay for such services from your Account Value, you must complete a form authorizing us to pay the amount requested by the third party from your Account Value. We will withdraw the requested payment according to the third party’s instructions, including instructions concerning from which Variable Account Options to withdraw the fee, and send you a confirmation of the transaction. We will not verify the accuracy of the amount being requested.

Assignments

We do not allow assignment of your contract.

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Death Benefit Paid on Death of Annuitant

Unlike some other variable annuities, our contract pays the Death Benefit upon the Annuitant’s death, rather than upon the owner’s death. (See section titled “Distribution on Death of Owner.”) You name the Annuitant’s beneficiary (or beneficiaries). We will pay a Death Benefit to the Annuitant’s surviving beneficiary if:

· the Annuitant dies before the Retirement Date; and

· there is no contingent Annuitant.

A Death Benefit won’t be paid after the Annuitant’s death if there is a contingent Annuitant. In that case, the contingent Annuitant becomes the new Annuitant under the contract. The Annuitant and any contingent Annuitants may not be changed once the contract has been issued.

If an Annuitant’s beneficiary doesn’t survive the Annuitant, then the Death Benefit is generally paid to the Annuitant’s estate.

The Annuitant’s beneficiary may elect to take the Death Benefit in one of the following forms:

1. lump sum — if the beneficiary elects this option, we will automatically pay the lump sum Death Benefit amount into a checking account in the name of the beneficiary, if allowed by state law. The checking account is an interest-bearing account with no fees. The beneficiary can access the funds at any time by writing a check.

2. deferral for up to five years — if the beneficiary elects this option, we will allow the beneficiary to keep the Death Benefit amount invested in the Investment Options available under the current version of the contract for a period of up to five years. At the end of five years, the entire amount must be paid to the beneficiary.

3. extending the contract — if the beneficiary elects this option, he or she must choose to receive the Death Benefit either as an immediate annuity or as substantially equal payments over his or her life expectancy. If payment over the life expectancy is elected, we will allow the beneficiary to keep the Death Benefit amount invested in the Investment Options available under the current version of the contract, to the extent this does not conflict with the Tax Code requirements under which this option is available (primarily section 72(s) of the Tax Code.) This option is only available if elected within 60 days of the date the beneficiary receives notice of the options. Distributions must begin within one year from the date of death.

If the beneficiary selects option two or three above, he or she will receive the guaranteed minimum interest rate applied to the Fixed Accounts under the current version of the contract, which may be lower than the guaranteed minimum interest rate applied to the Fixed Accounts in your contract.

If beneficiary is not a human being, the beneficiary must elect either a lump sum or deferral for up to five years.

You may change the Annuitant’s beneficiary by sending the appropriate form in Good Order to the Administrative Office. We may limit the number of beneficiaries you can have at one time.

Please consult your financial professional and tax advisor in order to identify your beneficiaries properly so that the Death Benefit is paid to the intended beneficiary, and to structure your contract so that spousal continuation can occur, if that is your intention. See Appendix D for assistance in structuring your contract.

Death Benefit

For contracts where the Annuitant’s age on the Contract Date (the date we issue you the contract, as indicated on your schedule page) is up to and including age 70, the Death Benefit will be the greater of:

(a) total contributions minus any a proportional adjustment for any withdrawals; or

(b) the Account Value at the end of the Business Day when we receive proof of death and the beneficiary’s instructions in good order.

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For contracts where the Annuitant’s age on the Contract Date is 71 years old or older, the Death Benefit is the current Account Value on the Business Day we receive due proof of death and the beneficiary’s instructions in good order.

Distribution on Death of Owner

When you (as owner) die, and the Annuitant (or contingent Annuitant) is still living, your entire interest in this contract must be distributed to the owner’s beneficiary. If you are the Annuitant (and no contingent Annuitant is still living), the above section titled “Death Benefit Paid on Death of Annuitant” applies instead of this section. If you own the contract jointly with your spouse or anyone else, the first death of one of the joint owners will be treated as the death of both owners, and a Distribution on Death to the owner’s beneficiary will be required. It is not a good idea to own this annuity contract jointly, even with your spouse. The joint owner is not the owner’s beneficiary. See Appendix D.

You name the owner’s beneficiary (or beneficiaries). We will pay the owner’s surviving beneficiary the Distribution on Death. If an owner’s beneficiary does not survive the owner, then the Distribution on Death of the owner is generally paid to the owner’s estate.

If you, as owner, die on or after the Retirement Date and before the entire interest in the contract has been distributed, then the rest of the annuity must be distributed to the owner’s beneficiary at least as quickly as the method in effect when you died.

If you, as owner, die before the Retirement Date, the Surrender Value will be paid to the owner’s beneficiary in one of the following forms:

1. lump sum — if the beneficiary elects this option, we will pay the Surrender Value to the beneficiary.

2. deferral for up to five years — if the beneficiary elects this option, we will allow the beneficiary to keep the Account Value invested in the Investment Options available under the current version of the contract for a period of up to five years. At the end of five years, the entire Surrender Value must be paid to the beneficiary.

3. extending the contract — if the beneficiary elects this option, he or she must choose to receive the Surrender Value either as an immediate annuity or as substantially equal payments over his or her life expectancy. If payment over the life expectancy is elected, we will allow the beneficiary to keep the Account Value invested in the Investment Options available under the current version of the contract, to the extent this does not conflict with the Tax Code requirements under which this option is available (primarily section 72(s) of the Tax Code.) This option is only available if elected within 60 days of the date the beneficiary receives notice of the options. Distributions must begin within one year from the date of the owner’s death.

If the beneficiary is not a human being, the beneficiary must elect either a lump sum or deferral for up to five years.

If your (owner’s) sole beneficiary is your spouse, your surviving spouse may be able to continue the contract (along with its tax-deferred status) in his or her name as the new owner. See the section below on Spousal Continuation and Appendix D.

You may change the owner’s beneficiary by sending the appropriate form in Good Order to the Administrative Office. We may limit the number of beneficiaries you can name. Please consult your financial professional and tax advisor in order to identify your beneficiaries properly so that the Death Benefit is paid to the intended beneficiary, and to structure your contract so that spousal continuation can occur, if

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that is your intention.

Spousal Continuation

If you (as owner) die, the Code allows your surviving spouse to continue the annuity contract, along with its tax-deferred status, so long as your spouse is your sole owner’s beneficiary.

This contract also provides enhanced spousal continuation if you have structured your contract as follows:

· you are the sole owner and Annuitant;

· no contingent Annuitant is named; and

· your spouse is the owner’s sole beneficiary and the Annuitant’s sole beneficiary.

Federal Tax Advantages of Spousal Continuation Not Available to Same Sex Spouses

The Federal Defense of Marriage Act provides that same sex spouses are not considered married under federal law. Therefore, the favorable tax treatment provided by the Tax Code to a surviving spouse of an annuity owner is not available to a surviving same sex spouse. If the state where this contract is issued recognizes same sex marriages, the Enhanced Spousal Continuation described in the contract is available to the surviving same sex spouse; however, the favorable tax treatment provided by the Tax Code will not apply and the transfer of ownership will be a taxable event.

Death Claims

A death claim must be filed to receive either the Death Benefit on the death of the Annuitant or a distribution of the Surrender Value on the death of the owner. A death claim will be effective on the Business Day we receive due proof of death of either the owner or Annuitant. To process the death claim, we must receive an original, certified death certificate and Company death claim paperwork in Good Order, including the beneficiary’s election. During the period from the date of death until we receive all required paperwork in Good Order, the Account Value will remain invested in the Investment Options you chose, will continue to reflect the investment performance of any Variable Account Options during this period and will be subject to market fluctuations. Fees and expenses will continue to apply. All automated transactions will stop when we receive notice of death.

If there are multiple beneficiaries, after one beneficiary submits death claim paperwork, we will calculate the first beneficiary’s share of the Death Benefit or Distribution on Death and make payment according to the first beneficiary’s election. The remaining beneficiaries’ share of the Death Benefit or Distribution on Death of owner will remain invested in the Investment Options and investment in the Variable Account Options remains subject to market fluctuations.

Retirement Date and Annuity Benefit

Your Annuity Benefit under this contract is calculated as of the Retirement Date you select. You can change the Retirement Date to a date no later than the last Annuitant’s 100th birthday (Maximum Retirement Date) by writing to the Administrative Office any time before the Maximum Retirement Date. Contract terms that apply to the various retirement programs, along with the federal tax laws and state insurance laws, establish certain minimum and maximum retirement ages. If your contract is a qualified retirement plan (including an IRA), distributions may continue beyond the Maximum Retirement Date.

Upon your Retirement Date, you may elect to receive a lump sum of your Surrender Value, or you may elect an Annuity Benefit. The amount applied toward the purchase of an Annuity Benefit will be the Account Value, less any pro-rata annual administrative charge.

Once an Annuity Benefit is elected, you will no longer have an Account Value, Death Benefit or other accessible cash value. When the contract value is applied toward the purchase of an Annuity Benefit, it is converted into a stream of income payments. The Annuity Benefit provides regular fixed payments, which may be made monthly, quarterly, semi-annually or annually. You cannot change or redeem the annuity once

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payments have begun. For any annuity, the minimum periodic payment must be at least $100.

We currently offer the following types of annuity payout options, funded through our General Account:

· life and 10-year certain annuity, which provides a fixed life income annuity with 10 years of payments guaranteed. If the Annuitant dies before the end of the 10 year period, the Annuitant’s beneficiary will receive the remaining periodic payments.

· period certain annuity, which provides for fixed payments for a fixed period. The fixed periods available may vary from time to time and the fixed period selected may not extend past your 100th birthday. The payment amount is determined by the period you select. If the Annuitant dies before the end of the period selected, the Annuitant’s beneficiary will receive the remaining periodic payments.

· life and period certain annuity (other than 10 years), which provides for fixed payments for at least the period selected and after that for the life of the Annuitant or the lives of the Annuitant and any joint Annuitant under a joint and survivor annuity. The fixed periods available may vary from time to time. If the Annuitant (or the Annuitant and the joint Annuitant under a joint and survivor annuity) dies before the period selected ends, the remaining periodic payments will go to the Annuitant’s beneficiary.

· life only annuity, which provides fixed payments for the life of the Annuitant, or until the Annuitant and joint Annuitant both die under a joint and survivor annuity. Once the Annuitant (or last joint Annuitant) dies, no further payments will be made and no value remains for any beneficiaries.

If you have not already selected a form of Annuity Benefit, we will contact you prior to your Maximum Retirement Date. You can tell us at that time the type of Annuity Benefit you want. If we do not receive your election on or before your Maximum Retirement Date, you will automatically receive a life and 10-year certain Annuity Benefit option.

You may not apply a portion of your Account Value to an Annuity Benefit.

Annuity Benefit Payments

The amount of your Annuity Benefit is based on the option you choose, the annuity rates applied and, in the case of a life contingent annuity option, on the Annuitant’s age and gender. Gender may not be a factor under some tax favored retirement programs, and under certain state laws where gender-neutral rates apply.

If the age or gender of an Annuitant has been misstated, any benefits will be those that would have been purchased at the correct age and gender. Any overpayments or underpayments made by us will be charged or credited with interest at the rate required by your state. If we have made overpayments because of incorrect information about age or gender, we will deduct the overpayment from the next payment or payments due. We will add underpayments to the next payment.

Timing of Payment

We normally apply your Adjusted Account Value to the purchase of an Annuity Benefit, or send you partial or total withdrawals, within seven days after receipt of the required form at our Administrative Office. However, we can defer our action as to Account Value allocated to the Variable Account Options for any period during which:

(1) the New York Stock Exchange has been closed or trading on it is restricted;

(2) an emergency exists as determined by the SEC so that disposal of securities is not reasonably practicable or it is not reasonably practicable for the Separate Account fairly to determine the value of its net assets; or

(3) the SEC, by order, permits us to defer action in order to protect persons with interests in the Separate Account.

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How You Make Requests and Give Instructions

When you write to our Administrative Office, use the address listed in the Glossary of this prospectus. We can’t honor your requests unless they are in proper and complete form. Whenever possible, use one of our printed forms, which may be obtained from our Administrative Office.

Part 6 - Voting Rights

How Portfolio Shares Are Voted

Integrity is the legal owner of the shares of the Portfolios held by the Separate Account and, as such, has the right to vote on certain matters. Among other things, we may vote to elect a Portfolio’s Board of Directors, to ratify the selection of independent auditors for a Portfolio, and on any other matters described in a Portfolio’s current prospectus or requiring a vote by shareholders under the 1940 Act.

Whenever a shareholder vote is taken, we give you the opportunity to tell us how to vote the number of shares purchased as a result of contributions to your contract. We’ll send you Portfolio proxy materials and a form for giving us voting instructions.

If we don’t receive instructions in time from all owners, we’ll vote shares in a Portfolio for which we have not received instructions in the same proportion as we vote shares for which we have received instructions. As a result of this proportional voting, the vote of a small number of contract owners may determine the outcome of a proposal. Under eligible deferred compensation plans and certain qualified plans, your voting instructions must be sent to us indirectly, through your employer, but we aren’t responsible for any failure by your employer to ask for your instructions or to tell us what your instructions are. We’ll vote any Portfolio shares that we’re entitled to vote directly, because of amounts we have accumulated in our Separate Account, in the same proportion that other owners vote. If the federal securities laws or regulations or interpretations of them change so that we’re permitted to vote shares of the Portfolios in our own right or to restrict owner voting, we may do so.

If shares of the Portfolios are sold to separate accounts of other insurance companies, the shares voted by those companies in accordance with instructions received from their contract holders will dilute the effect of voting instructions received by us from our owners.

How We Determine Your Voting Shares

You vote only on matters concerning the Portfolios which correspond to the Variable Account Options in which your contributions are invested on the record date set by the Portfolio’s Board of Directors. We determine the number of Portfolio shares in each Variable Account Option under your contract by dividing the amount of your Account Value allocated to that Variable Account Option by the net asset value of one share of the corresponding Portfolio as of the record date set by a Portfolio’s Board for its shareholders’ meeting. We count fractional shares. The record date for this purpose can’t be more than 60 days before the shareholders’ meeting. All Portfolio shares are entitled to one vote; fractional shares have fractional votes.

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Part 7 - Tax Aspects of the Contract

Introduction

The effect of federal income taxes on your annuity contract values, withdrawals and Annuity Benefit payments under your Annuity Benefits varies depending on many factors including:

· our tax status

· the tax status of the contract

· the type of retirement plan, if any, for which the contract is purchased

· the tax and employment status of the persons receiving payments

The following discussion of the federal income tax treatment of an annuity contract is not designed to cover all situations and is not intended to be tax advice. It is based upon our understanding of the present federal income tax laws as currently interpreted by the Internal Revenue Service (IRS) and various courts. The IRS or the courts may change their views on the treatment of these contracts. Future legislation may have a negative effect on annuity contracts. Also, we have not attempted to consider the effect of any applicable state or other tax laws.

Tax laws are complex and they differ depending on whether you own a Qualified or Nonqualified Annuity. It is important to remember that tax results vary depending on your particular circumstances. If you are considering buying an annuity contract, making a withdrawal from an annuity contract or selecting an Annuity Benefit, you should consult a qualified tax advisor about your individual situation. Integrity does not provide tax advice or guarantee the federal, state, or local tax status of any contract or any tax treatment of any transaction involving its contracts.

Your Contract is an Annuity

· You can purchase a Nonqualified Annuity with after-tax dollars. Taxes on earnings under the Nonqualified Annuity are generally deferred until you make a withdrawal.

· You can purchase a Qualified Annuity with after-tax dollars to fund a Roth IRA. The earnings under a Roth IRA are generally fully excluded from taxable income at distribution, subject to certain rules and limitations.

· You can purchase a Qualified Annuity with pre-tax dollars, such as a traditional IRA, or you can contribute pre-tax dollars to an annuity used to fund a qualified retirement plan, such as a 401(k) plan. Withdrawals from these annuity contracts are generally fully taxable as ordinary income.

This prospectus discusses the basic federal tax rules that apply to Nonqualified Annuities and touches on a few of the special tax rules that apply to Qualified Annuities.

Taxation of Annuities Generally

Section 72 of the Tax Code governs the taxation of annuities. In general, contributions you put into a Nonqualified Annuity (your “basis” or “investment in the contract”) will not be taxed when you receive those amounts back in a distribution. You are not generally taxed on the annuity’s earnings until some form of withdrawal or distribution is made under the contract. However, under certain circumstances, the increase in value may be subject to current federal income tax. For example, corporations, partnerships, and other non-human owners cannot defer tax on the annuity’s earnings unless an exception applies. In addition, if an owner transfers an annuity as a gift to someone other than a spouse(3) (or to a former spouse under a court order), all increases in its value are taxed at the time of transfer. The assignment or pledge of any portion of the value of an annuity contract will be treated as a distribution of that portion.

You can take withdrawals from your contract or you can elect an Annuity Benefit. For a Nonqualified Annuity, the tax implications are different for each type of distribution:

(3) Under current federal law, spouse means opposite-sex spouse only.

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· Withdrawals from a contract before Annuity Benefit payments begin are treated as taxable income to the extent of any gain in the contract. Withdrawals after all the gain is withdrawn represent your investment in the annuity and are not taxable. Generally, your investment in the contract equals the contributions you make minus any amounts previously withdrawn that were not treated as taxable income. Special rules may apply if the contract includes contributions made prior to August 14, 1982 that were transferred to the contract as a tax free exchange.

· If you elect an Annuity Benefit, part of each payment will be the tax-free return of your investment in the contract, based on a ratio of your investment to the your expected return under the contract (exclusion ratio). The rest of each payment will be taxed as ordinary income. That means that part of each annuity payment is tax-free and part is taxable. When all of these tax-free portions add up to your investment in the contract, all remaining payments are taxed as ordinary income. If the annuity payments end before the total investment is recovered, a deduction for the remaining basis will generally be allowed on the owner’s final federal income tax return.

We may be required to withhold federal income taxes on all distributions unless the eligible recipients elect not to have any amounts withheld and properly notify us of that election.

You may be subject to a tax penalty of 10% on the taxable portion of a distribution from either a Qualified or Nonqualified Annuity unless one of the following conditions apply:

· you are 59½ or older

· payment is a result of the owner’s death

· payment is a result of the owner becoming disabled within the meaning of Tax Code section 72(m)(7)

· payment is part of a series of substantially equal periodic payments paid at least annually, where the amount is determined by the life expectancy of the owner or joint life expectancy of the owner and a beneficiary payment is under a qualified funding asset as defined in Section 130(d) of the Tax Code

· payment is under certain types of qualified plans held by the employer until the employee separates from service

· payment is under an immediate annuity as defined in Tax Code Section 72(u)(4) (Nonqualified Annuities only)

· payment is for the purchase of a first home (distribution up to $10,000) (IRA only)

· payment is for certain higher education expenses (IRA only)

· payment is for certain deductible medical expenses (IRA only)

· you have received unemployment compensation under a federal or state program for at least 12 consecutive weeks and the distributions do not exceed the amount paid for health insurance coverage for yourself, your spouse and your dependents (IRA only).

The IRS will treat all annuity contracts issued by us or our affiliates to one owner during any calendar year as a single contract in measuring the taxable income that results from surrenders and withdrawals under any one of the contracts.

Tax-Favored Retirement Programs

An owner can use this annuity with certain types of qualified retirement plans that receive favorable tax treatment under the Tax Code. Numerous tax rules apply to the participants in qualified retirement plans and to the contracts used in connection with those plans. These tax rules vary according to the type of plan and the terms and conditions of the plan itself, regardless of the terms and conditions of the contract. Special rules also apply to the time at which distributions must begin and the form in which the distributions must be paid. Also, we do not offer loans through our annuity contracts even if the qualified plan allows for them.

Annuities in Qualified Plans

IRAs and qualified retirement plans, such as 401(k) plans, provide you with tax-deferred growth and other tax

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advantages. If you are investing in a variable annuity through a qualified retirement plan (such as a 401(k) or IRA), you will get no additional tax advantage from the variable annuity. Under these circumstances, consider buying a variable annuity only if it makes sense because of the annuity’s other features, such as the Death Benefit or Annuity Benefit.

Required Minimum Distributions (RMDs)

If you have a Qualified Annuity (other than a Roth IRA), you may need to withdraw money from this annuity contract in order to satisfy the RMDs required by the Tax Code after you turn 70½. We will calculate the RMDs with respect to this annuity contract based on the prior calendar year-end fair market value of this annuity contract only. We do not take into account your other assets or distributions in making this calculation. You should discuss these matters with your tax advisor.

Failure to comply with the RMD rules applicable to qualified contracts may result in the imposition of an excise tax. This excise tax generally equals 50% of the amount by which an RMD exceeds the actual distribution from the contract.

Roth IRAs do not require distributions at any time prior to the owner’s death.

Inherited IRAs

The death benefit paid under this contract may be extended as an inherited IRA. This occurs if, after the death of the owner of an IRA, the owner’s beneficiary directs that the death proceeds be titled as an inherited IRA. The owner’s beneficiary on the original IRA contract will become the inherited IRA owner and may name his or her own beneficiary in the event of death.

The inherited IRA owner may invest in the Investment Options available under the current version of the contract. Fees and charges will continue to apply and no additional contribution can be made. The inherited IRA owner must take RMDs beginning on or before December 31 of the calendar year after the original owner’s death. If the beneficiary is a spouse and has elected this option, distributions may begin at the end of the calendar year in which the owner would have reached age 70½, if later.

Exchanges and Transfers

In some circumstances, you may move money tax-free from one annuity to another. Money can be moved from one Nonqualified Annuity to another under section 1035 of the Tax Code. This is usually called a “1035 exchange.” Money can be moved from an IRA or from other qualified plan, such as a 401(k) plan or 403(b) tax sheltered annuity, to another IRA. This may be done by means of a rollover or a trustee-to-trustee transfer.

You cannot roll over from a SIMPLE IRA during the first two years of participation in the SIMPLE IRA and you cannot roll over after-tax contributions that are included in the other plans.

Tax laws are complex and your individual situation is unique. You should always consult a tax advisor before you move or attempt to move assets from one annuity to another annuity, contract or plan.

Federal and State Income Tax Withholding

We are required to withhold federal income taxes on all distributions from your annuity contract. If you are eligible, you may elect not to have any amounts withheld if you provide notice to us in Good Order. Also, certain states have indicated that we must apply withholding to payments made to their residents. Generally, an election out of federal withholding will also be considered an election out of state withholding.

Impact of Taxes on the Company

We may charge the Separate Account for taxes. We can also set up reserves for taxes.

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Part 8 — Additional Information

Systematic Withdrawal Program

We offer a program that allows you to pre-authorize periodic withdrawals from your contract prior to your Retirement Date. You can choose to have withdrawals made monthly, quarterly, semi-annually or annually and can specify the day of the month (other than the 29th, 30th or 31st) on which the withdrawal is to be made. If you do not select how often you want to receive withdrawals, we will make them on a monthly basis. You may specify a dollar amount or an annual percentage to be withdrawn. The minimum Systematic Withdrawal is $100. If you do not have enough Account Value to make the withdrawal you have specified, no withdrawal will be made and your enrollment in the program will end. You may specify an account for direct deposit of your Systematic Withdrawals. Direct deposit is required for monthly withdrawals. Withdrawals under this program are subject to income tax and a 10% tax penalty if you are under age 59½ (see Part 7.)

To enroll in our Systematic Withdrawal Program, send the appropriate form to our Administrative Office. You may terminate your participation in the program upon prior written notice. We may terminate or change the Systematic Withdrawal Program at any time.

Income Plus Withdrawal Program

We offer an Income Plus Withdrawal Program that allows you to pre-authorize substantially equal periodic withdrawals, based on your life expectancy as defined by the Tax Code, from your contract anytime before you reach age 59½. You will not have to pay a tax penalty for these withdrawals, but they will be subject to ordinary income tax. See Part 7. Once you begin receiving your withdrawals under this program, you should not change or stop the withdrawals until the later of:

· the date you reach age 59½; and

· five years from the date of the first withdrawal under the program.

If you change or stop the withdrawals or take an additional withdrawal, you may have to pay a 10% penalty tax that would have been due on all prior withdrawals made under the Income Plus Withdrawal Program before you reached the date described above, plus interest.

You can choose the Income Plus Withdrawal Program any time before you reach age 59½. You may choose to have withdrawals made monthly, quarterly, semi-annually or annually and may specify the day of the month (other than the 29th, 30th or 31st) on which the withdrawal is made. You may specify an account for direct deposit of your withdrawals. Direct deposit is required for monthly withdrawals. We will calculate the amount of the withdrawal, subject to a $100 minimum. We are not responsible for any tax or other liability you may incur if our good faith calculations are not correct. You should consult with your tax advisor to ensure these withdrawals are appropriate to your situation.

If on any withdrawal date you do not have enough Account Value to make the withdrawals you specified, no withdrawal will be made and your enrollment in the program will end.

To enroll in our Income Plus Withdrawal Program, send the appropriate form to our Administrative Office. You may end your participation in the program upon prior written notice. We may terminate or change the Income Plus Withdrawal Program at any time. This program is not available in connection with the Systematic Withdrawal Program.

Choices Plus Required Minimum Distribution (RMD) Program

We offer a Choices Plus RMD Program that allows you to pre-authorize withdrawals from your Qualified Annuity contract (such as a traditional IRA) after you attain age 70½. The Tax Code requires that you take minimum distributions from most Qualified Annuity contracts beginning on or before April 1st of the calendar year following the calendar year in which you turn 70½ years old. These withdrawals are subject to ordinary

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income tax. See Part 7.

You can choose the Choices Plus RMD Program at any time if you are age 70½ or older, by sending the election form to our Administrative Office. You can choose to have withdrawals made monthly, quarterly, semi-annually, or annually and can specify the day of the month (other than the 29th, 30th, or 31st) on which the withdrawal is made. You may specify an account for direct deposit of your withdrawals. Direct deposit is required for monthly withdrawals. We will calculate the amount of the withdrawals using current IRS guidance. We are not responsible for any tax or other liability you may incur if our good faith calculations are not correct. You should consult with your tax advisor to ensure these withdrawals are appropriate to your situation.

You may end your participation in the program upon prior written notice. We may terminate or change the Choices Plus RMD Program at any time.

Legal Proceedings

Integrity is a party to litigation and arbitration proceedings in the ordinary course of its business. None of these matters is expected to have a material adverse effect on Integrity.

Table of Contents of Statement of Additional Information

General Information and History		1
Administration and Distribution of the Contracts		1
Performance Data and Illustrations		2
Distributions Under Tax-Favored Retirement Programs		4
Financial Statements		4

If you would like to receive a copy of the Statement of Additional Information, please write:

Administrative Office

Integrity Life Insurance Company

P.O. Box 5720

Cincinnati, Ohio 45201-5720

ATTN: Request for Statement of Additional Information of Select Ten Plus

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Appendix A

CONDENSED FINANCIAL INFORMATION

The table below shows the Unit Value for certain Variable Account Options at inception, the number of Units outstanding at December 31 of each year since inception, and the Unit Value at the beginning and end of each period.

	2010		2009		2008		2007		2006		2005		2004		2003		Inception
Touchstone VST Large Cap Core Equity (465)*
Unit value at beginning of period	$	10.71	$	8.75	$	13.69	$	13.18	$	10.56	$	11.04	$	10.64	—		$	10.00
Unit value at end of period	$	11.86	$	10.71	$	8.75	$	13.69	$	13.18	$	10.56	$	11.04	$	10.64
Number of units outstanding at end of period	656,872		762,444		917,474		494,720		634,670		1,078,127		1,355,134		1,681,322

* Units include those belonging to owners of the Pinnacle III variable annuity

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Name:

Address:



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