October 31, 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.  Please note these responses
have added additional  information and  clarification to the response of October
20, 2005.

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.

With the above stated,  the Company  agrees in future filings to estimate to the
best of its ability projected future cashflows  relating to the liability Future
policy benefits.  Along with these  estimates,  the Company intends to include a
disclaimer  substantially  as  follows,  "estimates  of future  policy  benefits
presented  are based on  historic  trend  analysis  and  actuarially  determined
estimates of future results.  Actual results could vary significantly from these
estimates  resulting  in a  material  impact  on  the  Company's  liquidity  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.

Future filings will include a statement to the effect a more detailed  breakdown
of revenues from each product is impracticable.

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

Sincerely,

/s/ Theodore C. Miller

Theodore C. Miller
Sr. Vice President