October 20, 2005


Ibolya Ignat, Staff Accountant
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549

Dear Ms. Ignat:

I am writing as a  follow-up  to our recent  telephone  conversation.  Following
please find our responses to your latest inquiries.

Question 2 response - Additional clarification

Future policy  benefits  reflected as  liabilities of the Company on its balance
sheet as of December  31,  2004,  included in Item 8 of this  report,  represent
actuarial estimates of liabilities of future policy obligations such as expected
death claims on the insurance  policies in force as of the  financial  reporting
date. Due to the nature of these  liabilities,  maturity is event  dependent and
therefore,  these  liabilities  have been classified as having an  indeterminate
maturity.

The  Company  is unable to  estimate  with any  certainty  the  annual  expected
settlement of the future policy benefits  liability.  Maturity of this liability
is event  dependent  based on the  individual  insured under each policy.  Death
claims and cash value surrenders  represent the two most significant events that
lead to the payment by the  Company.  Life  insurance  products  are  considered
unilateral  contracts.  The policy  owner has  ultimate  control as regards  the
contract.  Generally,  as long as the  premiums  are paid as required  under the
policy, the Company cannot cancel the policy contract, only the policy owner can
cancel.  The contract generally is terminated either by the death of the insured
or by a request to surrender the policy by the owner. Either event is not within
the control of the Company,  making estimating these events with any accuracy or
certainty  difficult if not impossible.  Significant  changes in death claims or
cash surrender  requests could have an impact either positive or negative on the
Company's liquidity needs and financial condition.

Question 4 - Additional clarification

The Company offers various life insurance products to its customers.  We believe
these product offerings are similar and represent a single marketplace.  All are
to provide  protection on the life of the individual  insured.  Each product may
have slightly varied options such as face amount of policy  available or premium
payment  options,  but all remain  similar in nature overall and target the same
groups of clients.

A more  detailed  breakdown of revenues from each product is  impracticable  and
would result in an undue hardship to the Company.

Please  contact  me should  you have any  additional  questions  regarding  this
supplemental response.

Sincerely,

/s/ Theodore C. Miller

Theodore C. Miller
Sr. Vice President