Exhibit III.A.1.

             American Capitol Assumption Agreement

                        Exhibit III.A.1.

      Identification of American Capitol Assumed Policies


     The American Capitol Assumed 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.