SEC Company Response from RIVERSOURCE OF NEW YORK ACCOUNT 8 (CIK 0000817132) — Dec 13, 2004
RIVERSOURCE OF NEW YORK ACCOUNT 8 (CIK 0000817132)
Date: Dec. 13, 2004 · CIK: 0000817132 · Accession: 0000820027-04-001036
AI Filing Summary & Sentiment
File numbers found in text: 333-42257, 333-44644, 811-05213
Letter
VIA EDGAR and FACSIMILE (Correspondence Filing) IDS Life of New York Succession Select Variable Life Insurance Post-Effective Amendment No. 11 On From N-6 (File No. 333-42257) Investment Company Act No. 811-05213 IDS Life of New York Variable Universal Life IV/IDS Life of New York Variable Universal Life IV - Estate Series and IDS Life of New York Variable Universal Life III Post-Effective Amendment No. 10 On Form N-6 (File No. 333-44644) Investment Company Act No. 811-05213 IDS Life Of New York Variable Universal Life Insurance Post-Effective Amendment Nos. 25 and 26 On Form N-6 (File No. 33-15290) Investment Company Act No. 811-05213
RE: IDS Life of New York Account 8 ("Registrant")
Dear Mr. Cowan:
This letter is in response to Staff's oral comments sent via voicemail on or about December 10, 2004 for the Registrant and Post-Effective Amendments (collectively, the "Amendments") listed above. Staff had no comments except the requirement to make the following representation on behalf of the Registrant:
In connection with the Amendments, IDS Life Insurance Company of New York, (the "Company") on behalf of the Registrant, hereby acknowledges the following:
The disclosures in the filing are the responsibility of the Company and the Company is fully responsible for the adequacy or accuracy of the disclosures in this filing. The Company represents to the Commission that comments made by the Commission, or the staff acting pursuant to delegated authority, or changes to disclosure in response to staff comments in the filing reviewed by the staff, do not foreclosure the Commission from taking any action with respect to the filing, and the Company represents that it will not assert this action as a defense in any proceeding initiated by the Commission or any person, under the federal securities laws of the United States.
If you have any additional questions, please call Mary Ellyn Minenko at 612-671-3678 or Simone Pepper at 612-671-2847.
Sincerely,
/s/ Heather M. Somers
-----------------------
Heather M. Somers
General Counsel
IDS Life Insurance Company of New York
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>idsny-corresp.txt
<DESCRIPTION>IDS LIFE OF NEW YORK ACCOUNT 8
<TEXT>
December 10, 2004
VIA EDGAR and FACSIMILE (Correspondence Filing)
Mark Cowan
Office of Insurance Products
Division of Investment Management
Securities and Exchange Commission
450 Fifth Street, N.W. (Mail Stop 5-6)
Washington, D.C. 20549-1004
ATTN: Document Control - Edgar
RE: IDS Life of New York Account 8 ("Registrant")
IDS Life of New York Succession Select Variable Life Insurance
Post-Effective Amendment No. 11
On From N-6 (File No. 333-42257)
Investment Company Act No. 811-05213
IDS Life of New York Variable Universal Life IV/IDS Life of New York
Variable Universal Life IV - Estate Series and IDS Life of New York
Variable Universal Life III
Post-Effective Amendment No. 10
On Form N-6 (File No. 333-44644)
Investment Company Act No. 811-05213
IDS Life Of New York Variable Universal Life Insurance
Post-Effective Amendment Nos. 25 and 26
On Form N-6 (File No. 33-15290)
Investment Company Act No. 811-05213
Dear Mr. Cowan:
This letter is in response to Staff's oral comments sent via voicemail on or
about December 10, 2004 for the Registrant and Post-Effective Amendments
(collectively, the "Amendments") listed above. Staff had no comments except the
requirement to make the following representation on behalf of the Registrant:
In connection with the Amendments, IDS Life Insurance Company of New York, (the
"Company") on behalf of the Registrant, hereby acknowledges the following:
The disclosures in the filing are the responsibility of the Company and
the Company is fully responsible for the adequacy or accuracy of the
disclosures in this filing. The Company represents to the Commission
that comments made by the Commission, or the staff acting pursuant to
delegated authority, or changes to disclosure in response to staff
comments in the filing reviewed by the staff, do not foreclosure the
Commission from taking any action with respect to the filing, and the
Company represents that it will not assert this action as a defense in
any proceeding initiated by the Commission or any person, under the
federal securities laws of the United States.
If you have any additional questions, please call Mary Ellyn Minenko at
612-671-3678 or Simone Pepper at 612-671-2847.
Sincerely,
/s/ Heather M. Somers
-----------------------
Heather M. Somers
General Counsel
IDS Life Insurance Company of New York
Cc: Mary Ellyn Minenko
Simone Pepper
</TEXT>
</DOCUMENT>