INVESTORS LIFE INSURANCE CO OF NORTH AMERICA SEPARATE ACC I
24F-2NT, 1999-02-25
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                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 Separate Account 1
                  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
- --------------------------------------------------------------------------------
3.       Investment Company Act File Number:         811-3470

         Securities Act File Number:        2-77712 and 2-84850


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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.

- --------------------------------------------------------------------------------
4(c).  [ ] Check box if this is the last  time the  issuer  will be filing  this
       Form.




                                                        -1-

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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):                                       $ 1,512,674   
                     
(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:                                          $ 6,708,120      
                                    
(iv)     Total available redemption credits [add       -      $Not Applicable
         items 5(11) and 5(iii):

(v)      Net sales -- if Item 5(i) is greater than
         Item 5(iv) [subtract Item 5(iv) from                  $ (5,195,446)  
                                                   
(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 24f-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 24f-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: .
- --------------------------------------------------------------------------------
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): +$
- --------------------------------------------------------------------------------
8.       Total of the amount of the  registration  fee due plus any interest due
         [line 5(viii) plus line 7].   =$ 0.00            
- --------------------------------------------------------------------------------
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
- --------------------------------------------------------------------------------

                                   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, 1998  

*Please print the name and title of signing officer below the signature.


                                                        -3-

<PAGE>







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
                  CIGNA Separate Account I

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  CIGNA Separate  Account I
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.  2-77712).  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 Separate  Account I, 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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