American Heritage Life Insurance Company
We submit rates and actuarial memoranda for the above referenced forms for your review and approval. These rates are new and correspond to our Group Critical Illness Insurance GVCIP1DC and GVCIC1DC, previously approved by your department on 7/31/2006.
This rate filing is a resubmission of previously withdrawn filing ALST-128274518, in which we attempted to submit rates for 4 different Group Critical Illness products. In response to the objection to that filing (dated 5/30/2012), please consider the following, in order of the items in the objection letter:
1. The master policy will be sitused in DC.
2. We have filed these rates in other states, and have received approval as outlined in the table attached under Supporting Documentation.
3. This product is targeting small and large employer groups. We do not, at this time, have any associations, unions or trusts to market to.
4. The Actuarial Memorandum being filed has been updated.
5. Per your suggestion, we are submitting rates for each product separately. The other products' rates will be sent under separate cover.