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December 16, 2002 Page 4 of 4

transaction and customer of the insurance company in question”. We wish to offer one comment,

however, to revise one of the “red flags”. In the fourth “red flag” listed in the Proposed Rule, reference is made to payment to a third party. In credit life insurance, payment is indeed at times made to a third party and therefore such a payment would not raise suspicions. We respectfully request a revision to this phrase to state “ . . . directed to an unrelated third party”. The addition of “unrelated” more accurately describes a suspicious circumstance under a life insurance policy situation.

We appreciate your attention to our views. Kindly address any questions concerning our submission to our attention (carlwilkerson@acli.com)(202-624-2118) (victoriafimea@acli.com) (202-624-2183).

Cordially,

Carl B. Wilkerson

Victoria E. Fimea

N:\LITIGATE\Fimea\Corr\MonLaundLetter12.doc

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