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                                     EXHIBIT

                              PERSONS CONTROLLED BY
                          OR UNDER COMMON CONTROL WITH
                                 THE REGISTRANT

Below is a list of persons directly or indirectly controlled by or under common
control with the Registrant and (i) the state of organization, (ii) the basis of
control, and (iii) the principal business for each entity:

ROBERT G. DAVIS (ATTORNEY-IN-FACT and Ultimate Controlling Person)
------ -- ----- -

P&C GROUP

1. UNITED SERVICES AUTOMOBILE ASSOCIATION (A Reciprocal Interinsurance Exchange)

The purpose of USAA is to provide insurance coverage (personal lines property
and casualty policies only) for eligible "members." Essentially, eligibility for
membership is limited to active duty, guard and reserve, commissioned,
non-commissioned, petty, and warrant officers of the United States Services,
employees and former USAA members.

2. ENTERPRISE INDEMNITY CAPTIVE INSURANCE COMPANY, INC. (Wholly-owned subsidiary
of United Services Automobile Association)

The purpose of this Arizona captive insurance company is to provide selected
insurance and reinsurance products to USAA companies.

3. USAA CASUALTY INSURANCE COMPANY (Wholly-owned subsidiary of United Services
Automobile Association)

The purpose of this company is to provide personal lines insurance coverage to
former dependents of USAA members, active duty, guard and reserve, enlisted
military personnel, and employees of USAA.

4. USAA CORPORATE ATTORNEY IN FACT, INC. (A Delaware non-insurance corporation)

The purpose of USAA CORPORATE ATTORNEY IN FACT, INC. is to be the corporate
attorney in fact of USAA Texas Lloyd's Company.

5. USAA COUNTY MUTUAL INSURANCE COMPANY (A Texas County Mutual insurer managed
by United Services Automobile Association)

The purpose of this company is to provide auto insurance to certain individuals
eligible for insurance in USAA and USAA CIC in Texas.

6. USAA GENERAL AGENCY, INC. (Wholly-owned subsidiary of United Services
Automobile Association)

This company was organized as a subsidiary of United Services Automobile
Association to act as a managing general insurance agency for flood insurance
offered through the National Flood Insurance Program.

7. USAA GENERAL INDEMNITY COMPANY (Wholly-owned subsidiary of United Services
Automobile Association)

The primary purpose of this company is to provide nonstandard automobile
insurance to certain risks eligible for insurance in USAA or USAA CIC, except in
California, where it provides automobile insurance to current and former
enlisted personnel.

8. USAA INSURANCE AGENCY, INC. (Texas) (Wholly-owned subsidiary of United
Services Automobile Association)

A Texas corporation organized to place coverage for USAA members and associate
members not offered by USAA P&C Group.

9. USAA LIMITED (Wholly-owned United Kingdom subsidiary of United Services
Automobile Association)

The primary purpose of the company is to provide certain personal lines
insurance coverages to members of United Services Automobile Association based
in the European Union.

LIFE GROUP

1. USAA LIFE INSURANCE COMPANY (DEPOSITOR) (Wholly-owned subsidiary of United
Services Automobile Association)

A Texas corporation organized to act as a life insurance company offering
complete life insurance products and services to the general public.

2. USAA LIFE GENERAL AGENCY, INC. (Wholly-owned subsidiary of USAA Life
Insurance Company)

A Colorado corporation organized to act as a general insurance agency for life
and health products offered by non-USAA companies. The products offered by this
company are available to the general public.

3. USAA LIFE INSURANCE COMPANY OF NEW YORK (Wholly-owned subsidiary of USAA Life
Insurance Company)

This company was organized to provide life insurance and annuity products to
residents of New York.

4. SEPARATE ACCOUNT OF USAA LIFE INSURANCE COMPANY (REGISTRANT) Investment
account organized under the laws of the State of Texas.

USAA Life Insurance Company is the depositor.

5. LIFE INSURANCE SEPARATE ACCOUNT OF USAA LIFE INSURANCE COMPANY (REGISTRANT)
Investment account organized under the laws of the State of Texas.

USAA Life Insurance Company is the depositor

CAPCO GROUP

1. USAA CAPITAL CORPORATION (Wholly-owned subsidiary of United Services
Automobile Association)

This company is a general purpose financing company for USAA, its subsidiaries
and affiliates and is organized as a Delaware corporation. It also acts as a
holding company for all USAA non-insurance companies (except USAA Funding
Company and USAA Property Holdings, Inc.) and therefore with respect to the
banking entities serves as a unitary savings and loan holding company.

2. USAA FUNDING COMPANY (Wholly-owned subsidiary of United Services Automobile
Association)

This company was initially and primarily organized to facilitate the acquisition
of preferred stock issued by USAA insurance companies.

3. USAA PROPERTY HOLDINGS, INC. (Wholly-owned subsidiary of United Services
Automobile Association)

This company was formed to invest in certain real estate limited partnerships
the assets of which are comprised of housing units which qualify for significant
federal tax credits.

BANK GROUP

1. USAA FEDERAL SAVINGS BANK (Wholly-owned subsidiary of USAA Capital
Corporation)

This company is organized to offer personal banking services to the general
public.

2. CAPITAL MANAGEMENT COMPANY (Wholly-owned indirect subsidiary of United
Services Automobile Association)

This company serves as a unitary savings and loan holding company of USAA
Federal Savings Bank.

3. USAA FINANCIAL SERVICES CORPORATION (Wholly-owned subsidiary of USAA Capital
Corporation)

This company is incorporated under the Utah Revised Business Corporation Act and
owns an inactive Utah Industrial Loan Company license.

ALLIANCE SERVICES GROUP

1. USAA ALLIANCE SERVICES COMPANY (Wholly-owned subsidiary of United Services
Automobile Association)

This company was organized to engage in the business of wholesale and retail
sales of goods and to provide consumer-oriented and travel agency services to
customers, subscribers and the general public.

2. USAA ALLIANCE SERVICES, L.P.

This partnership was organized to provide travel and discount buying services
through a limited partnership structure.

USAA owns 99% of the Partnership as a Limited Partner with the remaining 1%
owned by USAA Alliance Services Company as General Partner.

INVESTMENT GROUP

1. USAA INVESTMENT CORPORATION (Wholly-owned subsidiary of USAA Capital
Corporation)

This company serves as a holding company for USAA Investment Management Company
and USAA Transfer Agency Company.

2. USAA INVESTMENT MANAGEMENT COMPANY (Wholly-owned subsidiary of USAA
Investment Corporation)

This company serves as the investment manager, administrator, underwriter and
distributor of the USAA Family of Funds offered to the general public (presently
39). It carries out the funds' investment programs, markets their shares and
provides certain administrative services.

This company also provides investment management services for the investment
portfolios of United Services Automobile Association and its affiliated
companies. In addition, this company provides investment advisory services
through personal asset management products to high net worth individuals. This
company also offers discount brokerage services.

3. USAA TRANSFER AGENCY COMPANY (DBA: USAA SHAREHOLDER ACCOUNT SERVICES)
(Wholly-owned subsidiary of USAA Investment Corporation)

This company serves as a transfer agent to the USAA mutual funds.

FINANCIAL PLANNING GROUP

1. USAA FINANCIAL PLANNING SERVICES INSURANCE AGENCY, INC. (DBA: USAA FINANCIAL
PLANNING SERVICES, INC.) (Wholly-owned subsidiary of USAA Capital Corporation)

This company engages in the business of providing personalized financial
planning services to the general public. It also acts as an insurance agency
that can promote property and casualty insurance products and life and health
insurance products.

2. USAA FINANCIAL ADVISORS, INC. (Wholly-owned subsidiary of USAA Financial
Planning Services Insurance Agency, Inc.)

This company is a broker-dealer enabled to permit its representatives to promote
USAA securities products to its members.

REAL ESTATE GROUP

1. USAA REAL ESTATE COMPANY (Wholly-owned subsidiary of USAA Capital
Corporation)

This company engages in the business of acquisition, development, ownership and
sale of land, real estate and other property or real estate securities by
purchase, lease or otherwise, including real estate/financial services to its
affiliates, subsidiaries, and the general public.

2. LA CANTERA DEVELOPMENT COMPANY (Wholly-owned subsidiary of USAA Capital
Corporation)

This company owns, develops and sells land in the La Cantera development in
northwest San Antonio, Texas.