U.S. SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM 24F-2
Annual Notice of Securities Sold
Pursuant to Rule 24f-2
1. Name and Address of issuer:
Investors Life Insurance Company of North America
INA/Putnam Separate Account
701 Brazos Street
Austin, Texas 78701
2. Name of each series or class of funds for which this notice
is filed:
Not Applicable
3. Investment Company Act File Number: 811-2980
Securities Act File Numbers: 2-66266
4. Last day of fiscal year for which this notice is filed:
December 31, 1997
5. Not Applicable
6. Not Applicable
7. Number and amount of securities of the same class or series
which had been registered under the Securities Act of 1933
other than pursuant to rule 24f-2 in a prior fiscal year,
but which remained unsold at the beginning of the fiscal
year: $0.00
8. Number and amount of securities registered during the fiscal
year other than pursuant to rule 24f-2: $0.00
9. Number and aggregate sale price of securities sold during
the fiscal year: $363,352
10. Number and aggregate sale price of securities sold during
the fiscal year in reliance upon registration pursuant to
rule 24f-2: $363,352
11. Not Applicable
12. Calculation of registration fee:
(i) Aggregate sale price of securities sold during the
fiscal year in reliance on rule 24f-2: $363,352
(ii) Not Applicable
(iii) Aggregate price of shares redeemed or repurchased
during the fiscal year: $1,911,912
(iv) Not Applicable
(v) Net aggregate price of securities sold and issued
during the fiscal year in reliance on rule 24f-2:
($1,548,560)
(vi) Not Applicable
(vii) Fee Due: $0.00
13. Not Applicable
SIGNATURES
This report has been signed below by the following persons on
behalf of the issuer and in the capacities and on the dates
indicated.
By: \s\ Roberta A. Mitchell
Title: Senior Vice President
Date: February 11, 1998
February 11, 1998
Mr. Roy F. Mitte
President and Chief Executive Officer
Investors Life Insurance Company of North America
701 Brazos Street
Austin, Texas 78701
Re: Investors Life Insurance Company of North America
INA/Putnam Separate Account
Dear Mr. Mitte:
This is written in connection with the filing of the Rule 24f-2
Notice for Investors Life Insurance Company of North America's
INA/Putnam Separate Account dated February 11, 1998, herewith
(the "Notice") under Section 24(f) of the Investment Company Act
of 1940, as amended. The Notice proposes to make definite the
dollar amount of such Separate Account's variable annuity
contract interest (the "Securities") registered under the
Securities Act of 1933, as amended (Registration No. 2-66266). I
have been asked for my opinion whether such securities have been
legally issued, fully paid and are nonassessable.
In my capacity as Senior Vice President and General Counsel of
Investors Life Insurance Company of North America, I have
examined such records and documents pertaining to variable
annuity contracts issued by Investors Life Insurance Company of
North America and funded through its INA/Putnam Separate Account,
as well as applicable Federal and State laws, as in my judgment
are necessary and appropriate to enable me to formulate the
opinion sought. Based upon the foregoing, it is my opinion that
the Securities have been legally issued, provided that their
registration is made definite in number by filing the Notice with
the Securities and Exchange Commission on or before June 30,
1998. The Securities are fully paid and nonassessable.
Sincerely,
\s\ Theodore A. Fleron
Senior Vice President and General Counsel
