We respectfully submit the above referenced Rates and Actuarial Memorandum for use with forms R-03005DC, et al filed under corresponding SERFF filing #FDLT-129097217. 

The current status of the Form filing under SERFF filing #FDLT-129097217 is Closed/Withdrawn 8/28/13 with a note from Colin Johnson, which states: "NO NEED TO RESPOND. I have reviewed this form filing and can only approve this form filing after your corresponding rate filing is approved. I may withdraw this filing in the near future due to my time standard to approve filings. After the corresponding rate filing has been approved, please contact me at 202-442-7796 to request to reopen your form filing if this filing is withdrawn."