SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

      November 4, 2005

Mr. Roy T.K. Thung
President and Chief Executive Officer
Independence Holding Company
96 Cummings Point Road
Stamford, Connecticut   06902

      Re:	Independence Holding Company
		Form 10-K for Fiscal Year Ended December 31, 2004
		Filed March 16, 2005
      File No. 001-32244

Dear Mr. Thung:

      We have reviewed your August 23, 2005 response to our July
21,
2005 comment letter dated and have the following comments.  In our
comments, we have asked you to provide us with information so we
may
better understand your disclosure.  After reviewing this
information,
we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of ...

Critical Accounting Policies

Insurance Reserves

1. Please expand the proposed disclosures you provided in response
to
prior comment one to discuss the potential impact of the judgments
and uncertainties surrounding this estimate, consistent with
Section
V. of Financial Reporting Release 72 and as we had requested.  In
so
doing, please provide quantitative and qualitative disclosure
about
the impact that reasonably likely changes in each of the "key
assumptions" cited in your response underlying the estimate of
each
segment`s reserves would have on your results of operations,
financial position, and liquidity.  In addition, please provide
disclosure to clarify how you determine each of these "key
assumptions".
2. As your response to prior comment two indicated that you had
revised the prior year incurred amount for 2004, please illustrate
for us how the following would need to be modified to reflect this
revision and any other necessary revisions to the amounts for
prior
years:  (a) the disclosures your provided pursuant to paragraph 11
of
SOP 94-5 and (b) your discussion, in MD&A, about the effect of
changes in the reserves on your results of operations.

In addition, based on the extent of the modifications that would
need
to be made, please provide us your analysis supporting your
assertion
that the effect of the revision was not material to the accuracy
of
your overall disclosures with respect to reserves or the changes
in
them.

Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 1.  Significant Accounting Policies and Practices

(I)  Deferred Acquisition Costs ("DAC")
3. Regarding your response to prior comments three and four and
your
proposed    accounting policy disclosure regarding deferred
acquisition costs for traditional life insurance and other
premium-
paying policies, please explain to us the difference between
amortizing DAC "over the life of the business", as explained in
the
first sentence of  your proposed disclosure, and the amortization
period approximating "the estimated lives of the policies", as
explained in the last sentence, and how your policy complies with
paragraph 29 of SFAS 60.
4. Regarding your response to prior comments three and four and
your
proposed accounting policy disclosure regarding deferred
acquisition
costs for investment type contracts and interest-sensitive life
business, please address the following for us:

* Clarify how the quarterly adjusting "to reflect actual gross
margins experienced" differs from the annual review of "the
underlying assumptions that produce the prospective [estimated
gross
profits] on a best-estimate basis."  Clarify your description of
each
process so that it is clear that it complies with paragraph 25 of
SFAS 97 including whether you record a charge or credit to the
statement of operation to adjust total amortization to date using
revised assumptions and whether you use the revised assumptions
going
forward.

* Clarify what you mean by "prospective unlocking" and whether and
to
what extent this is the result of a premium deficiency, or clarify
the extent to which this relates to and is consistent with
paragraph
25 of SFAS 97.

* Tell us the quantitative impact that adjustments to DAC have had
on
your financial statements for each of the three years.  If the
impact
has been material or the potential impact to future periods is
reasonably likely to be material, provide critical accounting
estimate disclosures, consistent with Section V. of Financial
Reporting Release 72, about this.

*    *    *    *

      Please respond to the comment within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your response to our comment and provides requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.

      You may contact Ibolya Ignat, Staff Accountant, at (202)
551-
3656, or Oscar Young, Senior Accountant, at (202) 551-3622, if you
have questions regarding the comments.  In this regard, do not
hesitate to contact me, at (202) 551-3679.

	Sincerely,

	Jim B. Rosenberg
	Senior Assistant Chief
	Accountant

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Mr. Roy T.K. Thung
Independence Holding Company
November 4, 2005
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