Chicago New York
	Washington, DC
	London
	San Francisco
	Los Angeles
	Singapore vedderprice.com
November 6, 2019
	W. Thomas Conner Shareholder +1 202 312 3331 tconner@vedderprice.com

VIA EDGAR TRANSMISSION

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

Re: Initial Registration Statement on Form S-3

Brighthouse Life Insurance Company of NY

Brighthouse Shield^® Level Select 3-Year Annuity

To the Commission:

On behalf of Brighthouse Life Insurance Company of NY (the “Company”), we are transmitting for filing under the Securities Act of 1933, as amended, an initial registration statement on Form S-3 (the “Initial Registration Statement”) for certain individual single premium deferred index-linked separate account annuity contracts (the “Contracts”). Exhibits not included with this filing, and certain other information will be added, and clarifying or stylistic changes will be made, by pre-effective amendment.

The primary purpose for which the Initial Registration Statement is being filed is to register additional interests in the Contracts. Clarifying, editorial and/or updating changes may also be included.

If you have any questions or comments regarding the Initial Registration Statement, please call the undersigned at (202) 312-3331 or Nathaniel Segal at (312) 609-7747.

Very truly yours,

/s/ W. Thomas Conner

W. Thomas Conner

Shareholder

WTC

Attachment

cc: Michele H. Abate, Associate General Counsel, Brighthouse Financial, Inc.

Dionne Sutton, Corporate Counsel, Brighthouse Financial, Inc.

Nathaniel Segal, Counsel, Vedder Price P.C.

1401 I Street NW, Suite 1100  |  Washington, DC 20005  |  T +1 202 312 3320  |  F +1 202 312 3322

 Vedder Price P.C. is affiliated with Vedder Price LLP, which operates in England and Wales, Vedder  Price (CA), LLP, which operates in California, and Vedder Price Pte. Ltd., which operates in Singapore.