0001104659-06-028854.txt : 20151006 0001104659-06-028854.hdr.sgml : 20151006 20060428133400 ACCESSION NUMBER: 0001104659-06-028854 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20060428 FILER: COMPANY DATA: COMPANY CONFORMED NAME: UNION SECURITY INSURANCE CO CENTRAL INDEX KEY: 0000823533 IRS NUMBER: 810170040 STATE OF INCORPORATION: MN FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 500 BIELENBERG DRIVE CITY: WOODBURY STATE: MN ZIP: 55125 BUSINESS PHONE: 6517384000 MAIL ADDRESS: STREET 1: P O BOX 64284 CITY: ST PAUL STATE: MN ZIP: 55164 FORMER COMPANY: FORMER CONFORMED NAME: FORTIS BENEFITS INSURANCE CO DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: WESTERN LIFE INSURANCE CO DATE OF NAME CHANGE: 19920329 FILER: COMPANY DATA: COMPANY CONFORMED NAME: VARIABLE ACCOUNT D OF UNION SECURITY INSURANCE CO CENTRAL INDEX KEY: 0000826723 IRS NUMBER: 810170040 STATE OF INCORPORATION: MN FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: P O BOX 64284 CITY: ST PAUL STATE: MN ZIP: 55164 BUSINESS PHONE: 6127384496 MAIL ADDRESS: STREET 1: P O BOX 64284 CITY: ST PAUL STATE: MN ZIP: 55164 FORMER COMPANY: FORMER CONFORMED NAME: VARIABLE ACCOUNT D OF FORTIS BENEFITS INSURANCE CO DATE OF NAME CHANGE: 19920703 FORMER COMPANY: FORMER CONFORMED NAME: VARIABLE ACCOUNT D OF WESTERN LIFE INSURANCE CO DATE OF NAME CHANGE: 19920303 FILER: COMPANY DATA: COMPANY CONFORMED NAME: UNION SECURITY LIFE INSURANCE CO OF NEW YORK CENTRAL INDEX KEY: 0000914804 IRS NUMBER: 132699219 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: 308 MALTBIE STREET SUITE 200 CITY: SYRACUSE STATE: NY ZIP: 13204 BUSINESS PHONE: 3154510066 MAIL ADDRESS: STREET 1: 308 MLATBIE STREET SUITE 200 CITY: SYRACUSE STATE: NY ZIP: 13204 FORMER COMPANY: FORMER CONFORMED NAME: FIRST FORTIS LIFE INSURANCE CO DATE OF NAME CHANGE: 19931117 FILER: COMPANY DATA: COMPANY CONFORMED NAME: SEPARATE ACCOUNT A OF UNION SECURITY LIFE INS CO OF NEW YORK CENTRAL INDEX KEY: 0000914805 IRS NUMBER: 132699219 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: P O BOX 3209 STREET 2: 220 SALINA MEADOWS PARKWAY CITY: SYRACUSE STATE: NY ZIP: 13220 BUSINESS PHONE: 3154510066 MAIL ADDRESS: STREET 1: P O BOX 64284 STREET 2: FORTIS FINANCIAL GROUP CITY: ST PAUL STATE: MN ZIP: 55164 FORMER COMPANY: FORMER CONFORMED NAME: SEPARATE ACCOUNT A OF FIRST FORTIS LIFE INS CO DATE OF NAME CHANGE: 19940414 CORRESP 1 filename1.txt [Hartford Logo] April 28, 2006 VIA EDGAR Michael L. Kosoff Staff Attorney--Office of Insurance Products Division of Investment Management U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-4644 Re: Registration Statements on Form S-1/N-4 File Nos. 333-43799, 333-43805, 033-71686, 333-14761, 033-37577, 033-63799, 333-65233, 333-65231, 333-20343, 333-20345, 033-63935, and 033-63829 Dear Mr. Kosoff: In accordance with our discussions yesterday, attached please find black lined pages reflecting our responses to your comments on April 26 and 27, 2006. We hereby acknowledge that the Staff of the Commission has not passed upon the accuracy or adequacy of the prospectus and related statement of additional information for the above referenced registration statements. We acknowledge that the review of the filing by the Staff of the Commission does not relieve the registrant of its full responsibility for the adequacy and accuracy of the disclosure of this filing nor does it foreclose the Commission from taking any action with respect to the filing. Further, we acknowledge that the registrant may not assert as a defense in any proceeding initiated by the Commission or any person under federal securities law that the Staff of the Commission reviewed the filing and provided comments to the registrant or that the filing became automatically effective thereafter. We represent that these changes will be made to the form N-4 filings that relate to these S-1 filings that become effective on or around May 1, 2006. We further represent that the changes pertaining to the abusive trading restrictions will be reflected in the next post-effective amendment filed under all other Hartford insurance products to which this language change would be applicable. We appreciate your attention to this filing. We look forward to receiving your effectiveness order on or about May 1, 2005. If you have any further comments or questions, please call me at (860) 843- 1941. Very truly yours, /s/ Richard Wirth Richard Wirth Senior Counsel