SEC Company Response from ING USA ANNUITY & LIFE INSURANCE CO (CIK 0000836658) — Jun 28, 2005
ING USA ANNUITY & LIFE INSURANCE CO (CIK 0000836658)
Date: June 28, 2005 · CIK: 0000836658 · Accession: 0000950137-05-008004
AI Filing Summary & Sentiment
File numbers found in text: 333-123457
Letter
June 28, 2005 BY EDGAR AND FACSIMILE Securities and Exchange Commission Division of Corporation Finance Washington, D.C. 20549-0305 Attention: Mr. Max A. Webb
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) (the "Registration Statement") ---------------------------------------------------------------------
Dear Mr. Webb:
Pursuant to our telephone conversation of June 16, 2005, the purpose of this letter is to inform you that ING USA Annuity and Life Insurance Company has not, and will not, issue notes or funding agreements under the Registration Statement paying interest based on one or more stock indexes or similar indexes as contemplated by the last bullet point under "Summary - Terms of the Notes - Interest Rate" of the Institutional Prospectus Supplement and as contemplated by the last bullet point under "Summary - Terms of the Notes - Interest Rate" of the Retail Prospectus Supplement.
Very truly yours,
/s/ Eric G. Banta
---------------------
Eric G. Banta
Counsel
Show Raw Text
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[ING USA LETTERHEAD]
June 28, 2005
BY EDGAR AND FACSIMILE
Securities and Exchange Commission
Division of Corporation Finance
Washington, D.C. 20549-0305
Attention: Mr. Max A. Webb
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) (the "Registration Statement")
---------------------------------------------------------------------
Dear Mr. Webb:
Pursuant to our telephone conversation of June 16, 2005, the purpose of this
letter is to inform you that ING USA Annuity and Life Insurance Company has not,
and will not, issue notes or funding agreements under the Registration Statement
paying interest based on one or more stock indexes or similar indexes as
contemplated by the last bullet point under "Summary - Terms of the Notes -
Interest Rate" of the Institutional Prospectus Supplement and as contemplated by
the last bullet point under "Summary - Terms of the Notes - Interest Rate" of
the Retail Prospectus Supplement.
Very truly yours,
/s/ Eric G. Banta
---------------------
Eric G. Banta
Counsel
cc: Messeret Nega (Securities and Exchange Commission)
Russell Craig (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)
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