Section 204.EXHIBIT A   Initial Statement of Beneficial Ownership of Securities

 ILLINOIS DEPARTMENTAL REGULATIONS

STATE OF ILLINOIS

Director of Insurance

Form 1 – Instructions for Initial Statement of Beneficial Ownership of Securities

1.         Persons Required to File Statements

A statement on this form is required to be filed by every person who is directly or indirectly the beneficial owner of more than 10 percent of any class of equity security of an Illinois stock insurance company, or who is a director or an officer of such a company.

2.         When Statements Are to Be Filed.

(a)        Persons who hold any of the relationships specified in instruction 1 are required to file a statement by January 31, 1966, or within 10 days after assuming such relationship, whichever date is later.

(b)        Statements are not deemed to have been filed with the Director until they have actually been received by him.

3.         Where Statements Are to Be Filed.

One signed, sworn true copy of each statement shall be filed with the Director of Insurance, State of Illinois, Springfield, Illinois 62767.

4.         Separate Statements For Each Company.

A separate statement shall be filed with respect to the securities of each company.

5.         Relationship of Reporting Person to Company.

Indicate clearly the relationship of the reporting person to the company; for example, "Director", "Director and Vice President", "Beneficial owner of more that 10 percent of the company's common stock", etc.

6.         Date As of Which Beneficial Ownership Is To Be Given.

The information as to beneficial ownership of securities shall be given as of January 31, 1966, or, in the case of persons who subsequently assume any of the relationships specified in Instruction 1, as of the date that relationship was assumed.

7.         Title of Security

The statement of the title of a security shall be such as clearly to identify the security even though there may be only one class; for example, "Class A Common Stock", "5% Debentures Due 1965", etc.

8.         Nature of Ownership

Under "Nature of ownership", state whether ownership of the securities is "direct" or "indirect".  If the ownership is indirect, i.e., through a partnership, corporation, trust or other entity, indicate, in a footnote or other appropriate manner, the name or identity of the medium through which the securities are indirectly owned.  The fact that securities are held in the name of a broker or other nominee does not, of itself, constitute indirect ownership.  Securities owned indirectly shall be reported on separate lines from those owned directly and also from those owned through a different type of indirect ownership.

9.         Statement of Amount Owned.

In stating the amount of securities beneficially owned, give the face amount of debt securities or the number of shares or other units of other securities.  In the case of securities owned indirectly, the entire amount of securities owned by the partnership, corporation, trust or other entity shall be stated. The person whose ownership is reported may, if he so desires, also indicate in a footnote, or other appropriate manner, the extent of his interest in the partnership, corporation, trust or other entity.

10.       Inclusion of Additional Information.

A statement may include any additional information or explanation deemed relevant by the person filing the statement.

11.       Signature.

If the statement is filed for a corporation, partnership, trust, etc., the name of the organization shall appear over the signature of the officer or other person authorized to sign the statement.  If the statement is filed for an individual, it shall be signed by him or specifically on his behalf by a person authorized to sign for him.

In those cases where the statement is signed by someone other than the person whose ownership is being reported, documentary evidence of the signing authority shall be filed with the statement.

In all cases, the signature must be duly notarized.