Exhibit III.A.1.

              Texas Imperial Assumption Agreement

                            Exhibit III.A.1.

      Identification of Medicare Supplement Issue Age Policies

     The Medicare Supplement Issue Age policies have been identified
in a policyholder listing which is in the possession of the parties.
The information in those lists is confidential and not made a part of
the filing with the Court.  However, the policyholder information is
a part of the Assumption Agreements and is incorporated herein by
reference.