SEC Company Response from ING USA ANNUITY & LIFE INSURANCE CO (CIK 0000836658) — May 24, 2005
ING USA ANNUITY & LIFE INSURANCE CO (CIK 0000836658)
Date: May 24, 2005 · CIK: 0000836658 · Accession: 0000950137-05-006427
AI Filing Summary & Sentiment
File numbers found in text: 333-123457
Letter
May 24, 2005 BY EDGAR AND FACSIMILE Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549-0305 Attention: Ms. Messeret Nega
Re: ING USA Annuity and Life Insurance Company Registration Statement on Form S-3 filed March 18, 2005, as amended by Amendment No. 1 filed on April 22, 2005 and Amendment No. 2 filed on May 17, 2005 (File No. 333-123457)
Dear Ms. Nega:
In accordance with Rule 461 under the Securities Act of 1933, as amended, ING USA Annuity and Life Insurance Company (the "Registrant") hereby requests the acceleration of the effective date of the above-referenced Registration Statement so that it will become effective as soon as possible, in any event by Thursday, May 26, 2005 at 11:00 a.m., Eastern Time or as soon thereafter as practicable.
Please note the following:
o The Registrant acknowledges the disclosure in the filing is the responsibility of Registrant.
o The Registrant acknowledges to the Commission that should the Commission or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing.
o The Registrant acknowledges that the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective does not relieve the Registrant from its full responsibility for the adequacy and accuracy of the disclosures in the filing.
o The Registrant represents that it will not assert this action of the Commission or the staff, acting pursuant to delegated authority, as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
Very truly yours,
/s/ Eric G. Banta
-----------------------
Eric G. Banta
Counsel
Show Raw Text
<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
<PAGE>
[ING USA LETTERHEAD]
May 24, 2005
BY EDGAR AND FACSIMILE
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549-0305
Attention: Ms. Messeret Nega
Re: ING USA Annuity and Life Insurance Company
Registration Statement on Form S-3 filed March 18, 2005, as
amended by Amendment No. 1 filed on April 22, 2005 and
Amendment No. 2 filed on May 17, 2005 (File No. 333-123457)
Dear Ms. Nega:
In accordance with Rule 461 under the Securities Act of 1933, as amended, ING
USA Annuity and Life Insurance Company (the "Registrant") hereby requests the
acceleration of the effective date of the above-referenced Registration
Statement so that it will become effective as soon as possible, in any event by
Thursday, May 26, 2005 at 11:00 a.m., Eastern Time or as soon thereafter as
practicable.
Please note the following:
o The Registrant acknowledges the disclosure in the filing is the
responsibility of Registrant.
o The Registrant acknowledges to the Commission that should the Commission or
the staff, acting pursuant to delegated authority, declare the filing
effective, it does not foreclose the Commission from taking any action with
respect to the filing.
o The Registrant acknowledges that the action of the Commission or the staff,
acting pursuant to delegated authority, in declaring the filing effective
does not relieve the Registrant from its full responsibility for the
adequacy and accuracy of the disclosures in the filing.
o The Registrant represents that it will not assert this action of the
Commission or the staff, acting pursuant to delegated authority, as a
defense in any proceeding initiated by the Commission or any person under
the federal securities laws of the United States.
Very truly yours,
/s/ Eric G. Banta
-----------------------
Eric G. Banta
Counsel
cc: Max A. Webb (Securities and Exchange Commission)
Beth Edwards (ING USA Annuity and Life Insurance Company)
Perry Shwachman (Sidley Austin Brown & Wood LLP)
Anthony J. Ribaudo (Sidley Austin Brown & Wood LLP)
Jeff Delaney (Pillsbury Winthrop Shaw Pittman LLP)
</TEXT>
</DOCUMENT>