UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549
FORM 24F-2
Annual Notice of Securities Sold
Pursuant to Rule 24f-2
Read instructions at end of Form before preparing Form.
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1. Name and address of issuer:
Investors Life Insurance Company of North America
INA/Putnam Separate Account
701 Brazos Street, Suite 1400
Austin, TX 78701
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2. The name of each series or class of securities for which this Form is
filed (If the Form is being filed for all series and classes of
securities of the issuer, check the box but do not list series or
classes: [ ]
NOT APPLICABLE
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3. Investment Company Act File Number: 811-2980
Securities Act File Number: 2-66266
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4(a). Last day of fiscal year for which this Form is filed:
December 31, 1998
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4(b). [ ] Check box if this Form is being filed late (i.e., more than 90
calendar days after the end of the issuer's fiscal year). (See Instruction
A.2)
Note: If the Form is being filed late, interest must be paid on the registration
fee due.
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4(c). [ ] Check box if this is the last time the issuer will be filing this
Form.
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5. Calculation of registration fee:
(i) Aggregate sale price of securities sold
during the fiscal year pursuant to
section 24(f): $ 516,146
(ii) Aggregate price of securities redeemed
or repurchased during the fiscal year: $ Not Applicable
(iii) Aggregate price of securities redeemed
or repurchased during any prior fiscal
year ending no earlier than October 11,
1995 that were not previously used to
reduce registration fees payable to the
Commission: $ 2,738,427
(iv) Total available redemption credits [add
items 5(11) and 5(iii): $ Not Applicable
(v) Net sales -- if Item 5(i) is greater than
Item 5(iv) [subtract Item 5(iv) from $ (2,222,281)
(vi) Redemption credits available for use
in $ Not Applicable future years -- if
Item 5(i) is less than Item 5(iv)
[subtract Item 5(iv) from Item 5(i)]:
(vii) Multiplier for determining registration
fee (See Instruction c.(): x
(viii) Registration fee due [multiply Item
5(v) by Item (vii)] (enter "0" if no fee
is due): =$ 0.00
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6. Prepaid Shares
If the response to Item 5(i) was determined by deducting an amount of
securities that were registered under the Securities Act of 1933
pursuant to rule 24e-2 as in effect before October 11, 1997, then
report the amount of securities (number of shares of other units)
deducted here: . If there is a number of shares or other units that
were registered pursuant to rule 24e-2 remaining unsold at the end of
the fiscal year for which this form is filed that are available for use
by the issuer in future fiscal years, then state that number here: .
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7. Interest due -- if this Form is being filed more than 90 days after the
end of the issuer's fiscal year (see Instruction D): +$
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8. Total of the amount of the registration fee due plus any interest due
[line 5(viii) plus line 7]. =$ 0.00
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9. Date the registration fee and any interest payment was sent to the
commission's lockbox depository:
Method of Delivery:
[ ] Wire Transfer
[ ] Mail or other means
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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 (Signature and Title)* /s/Roberta A. Mitchell
Roberta A. Mitchell
Senior Vice President
Date February 22, 1999
*Please print the name and title of signing officer below the signature.
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February 22 , 1999
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 22, 1999, 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, 1999. The
Securities are fully paid and nonassessable.
Sincerely,
/s/Theodore A. Fleron
Theodore A. Fleron
Senior Vice President and General Counsel
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