Sutherland Asbill & Brennan LLP
1275 Pennsylvania Avenue, NW
Washington, DC 20004-2415

MARY E. THORNTON
DIRECT LINE: 202.383.0698
Internet: mary.thornton@sablaw.com

                              September 18, 2006

VIA EDGAR TRANSMISSION
______________________

Susan Nash, Esq.
Associate Director
Division of Investment Management
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549

Re: Registration Statements on Form N-6 for Metropolitan Life
    Separate Account UL (File No. 333-131664) and MetLife
    Investors USA Variable Life Account A (File No. 333-131665)
    ___________________________________________________________

Dear Ms. Nash:

On behalf of Metropolitan Life Insurance Company ("MetLife") and MetLife
Investors USA Insurance Company ("MLI") (together, the "Companies") and in
response to your recent questions, we have provided an overview of the
Advantage Equity Options riders under review by your office in the above
captioned Registration Statements on Form N-6. As you know, the Advantage
Equity Options are optional benefits provided by policy rider, which can be
elected by an owner of a specific fixed benefit insurance policy issued by
either of the Companies. As requested, we have attempted to provide additional
information in this letter regarding background on the existing Equity Options
riders and development of the Advantage Equity Options (along with the business
reasons for offering a variable rider in connection with a fixed policy), the
operation of these riders vis-a-vis the base policy, and the marketing plan for
Advantage Equity Options (including an explanation of why an investor
purchasing a fixed policy might elect to purchase Advantage Equity Options).



Susan Nash, Esq.
September 18, 2006
Page 2 of 5

BACKGROUND ON EXISTING EQUITY OPTIONS

MetLife currently issues a fixed benefit, traditional whole life insurance
policy, known as L-98, which offers a number of policy riders that can be added
to the policy to provide additional insurance coverage and other benefits. When
this product was being developed in 1997-98, MetLife sought to distinguish the
product from those of its competitors by designing unique rider benefits that
were not offered by those competitors' products. To this end, MetLife developed
two riders providing additional life insurance coverage, but whose cash value
is invested in one or two variable investment options selected by the policy
owner, rather than in MetLife's general account (known collectively as the
Equity Options). The SEC Staff granted effectiveness of the Equity Options
registration statement on May 1, 1998 (File No. 333-40161). In 2003, when the
registration statement was converted to Form N-6, the SEC Staff also reviewed
and provided comments on the Equity Options prospectus. MetLife has
continuously offered Equity Options for sale since 1998.

The Equity Options riders were designed for those policy owners who are
primarily interested in the guarantees provided by a fixed benefit policy, but
who desire some limited exposure to the equity markets. One of the Equity
Options riders (Equity Additions) is purchased exclusively with policy
dividends--a reflection of the ancillary role that that rider's cash value and
corresponding death benefit play vis-a-vis the cash value and the death benefit
of the underlying fixed benefit policy. And, although the second Equity Options
rider (Equity Enricher) is funded with the amount of rider premiums the policy
owner chooses, it was never envisioned, nor has it been the case, that the
rider's cash value and death benefit would amount to more than a fraction of
the total cash value and death benefit provided under the base policy. In fact,
the Company's experience has borne this out; based on a recent analysis, only
2.04% of the current owners of the L-98 product have purchased the Equity
Enricher rider. As of June 30, 2006, the total cash value of all outstanding
Equity Enricher riders was $6,380,791, which represents only 0.30% of the total
cash value of all outstanding L-98 polices, including policy riders.

DEVELOPMENT OF ADVANTAGE EQUITY OPTIONS

In 2005, MetLife began developing a new traditional whole life product to
replace the L-98 product. In order to make the new product as competitive and
versatile as possible, the Company's Product Management Department determined
that the new product should offer an even greater array of additional benefits
by rider, including redesigned versions of the Equity Options riders. As
redesigned, each Advantage Equity Option would offer five underlying investment
options, all of which are index portfolios. In addition, a fixed account option
would be added. MetLife could have filed a post-effective amendment under Rule
485(a) for the redesigned Equity Options, but in light of the uncertainty
surrounding the timing of state approvals of the underlying policy and the
Advantage Equity Options riders, it chose instead to file an initial
registration statement. On February 8, 2006, MetLife and its affiliate MLI each



Susan Nash, Esq.
September 18, 2006
Page 3 of 5

filed an initial registration statement with the Commission to register the
Advantage Equity Options. (The new whole life product and the Advantage Equity
Options will be issued by MetLife in New York and by MLI in all other states
and the District of Columbia.)

OPERATION OF ADVANTAGE EQUITY OPTIONS

The Advantage Equity Options are optional benefits provided by policy rider to
the underlying fixed benefit insurance policy. The fixed benefit insurance
policy is a separate stand-alone traditional whole life insurance policy and no
part of its cash value or death benefit varies in any way based on investments
in securities. A traditional whole life insurance policy provides permanent
lifetime insurance coverage through the payment of scheduled premiums that are
guaranteed in amount and payable until the insured's attained age 100. The
death benefit is guaranteed to the insured's age 120, as long as the scheduled
premiums are paid when due. Failure to pay a scheduled premium results in lapse
of the policy unless the premium is paid during the grace period. Premiums paid
into the policy are invested by a Company through its general account, but the
policy's cash value does not share in the investment experience of the general
account. Instead, the Companies guarantee that the cash value will be credited
with interest at a minimum rate of 4% per year. Because the policy is a
"participating policy," it will also be credited with any annual dividends that
are declared by the issuing Company's Board of Directors beginning in the
second policy year.

The Advantage Equity Options riders, if elected, are not part of the underlying
fixed benefit insurance policy. The cash values and death benefits associated
with the riders are completely separate from the cash value and the death
benefit provided under the base policy. The death benefit provided by the
Advantage Equity Options is based solely on the cash value in the variable
investment options and the fixed account option of the Advantage Equity
Options. (The fixed account is not available under the base policy.) The
Advantage Equity Options riders can be terminated at any time without affecting
the base policy values in any way. Under these circumstances, we feel it is
appropriate that only the riders be registered, and not the underlying fixed
benefit insurance policy. Under Section 3(a)(8) of the Securities Act of 1933,
the underlying fixed benefit insurance policy is not a security and should not
be registered as such. Although this structure may be unique, we believe it is
functionally equivalent to the general or fixed account options available under
many variable insurance products. Although the variable contact itself is
registered, the general or fixed account option that provides fixed benefits is
not registered.

Given that the Advantage Equity Options are policy riders, by their very
nature, they cannot exist apart from the underlying base policy. This means
that these riders will stay in force at much lower amounts than if they were
stand-alone variable life insurance policies. On the other hand, a surrender of
the base policy will be treated as a surrender of the Advantage Equity Options.
Similarly, if the base policy lapses, the riders, along with all other riders,
will lapse as well.



Susan Nash, Esq.
September 18, 2006
Page 4 of 5

Upon lapse, the Companies do not automatically cancel all benefits under the
policy and the Advantage Equity Options and return the remaining cash value to
the policy owner. The Companies must instead comply with state non-forfeiture
laws, which require that the remaining policy value be applied to provide
extended term insurance or a reduced paid-up insurance benefit. The Companies
can only pay out the remaining cash value in cash if the policy owner so
requests.

State non-forfeiture laws are designed for the protection of policy owners and
are intended to prevent the unintentional or forced loss of insurance coverage.
The Companies interpret these requirements as applying to the base policy and
any riders, including the Advantage Equity Options. Therefore, since the base
policy's benefits are frozen upon lapse, the Advantage Equity Options are
frozen through a transfer of the riders' cash value to the fixed account
option. The Companies will allow an additional period during which the unpaid
premium can be submitted in order to restore the policy. If such payment is not
received by the 90/th/ day after the initial non-payment of the premium, the
Companies will apply the cash value of the base policy and the cash value of
the Advantage Equity Options to the non-forfeiture options selected by the
policy owner, or in the absence of an election, to the extended term insurance
option.

MARKETING PLAN FOR ADVANTAGE EQUITY OPTIONS

The new traditional whole life product, similar to its predecessor L-98, will
be marketed to those individuals seeking the guarantees of a fixed benefit life
insurance product. A purchaser will have the option of electing either or both
Advantage Equity Options. Advantage Equity Additions can only be purchased by
using dividends paid on the underlying fixed benefit policy. It cannot be
purchased with premiums payments. For policy owners looking for a limited
investment in the securities markets without any out-of-pocket cash outlay,
Advantage Equity Additions may be appropriate. Advantage Equity Enricher, on
the other hand, is purchased with premium payments. For a policy owner looking
to invest more than the amount of the policy dividends, while still enjoying
the guarantees provided by the underlying fixed benefit policy, Advantage
Equity Enricher may be appropriate. A sales load and an expense charge apply to
Advantage Equity Enricher, but not to Advantage Equity Additions. The Companies
pay compensation to registered representatives only with regard to Advantage
Equity Enricher.

If the prospective purchaser is primarily interested in and suited to the
features and potential benefits of a variable life insurance policy, there are
a number of registered variable life insurance products issued by the Companies
and their affiliates from which the purchaser can choose. There would be no
reason for a sales representative to offer the new whole life insurance policy
and the Advantage Equity Options in lieu of one of these variable insurance
products. Furthermore, the Companies' suitability review process would insure
that purchasers obtain the type of coverage that is most appropriate for them.



Susan Nash, Esq.
September 18, 2006
Page 5 of 5

                                     * * *

We hope you find this overview satisfactory. The Companies are anxious to
resolve any remaining issues in order to have these registration statements
declared effective as soon as possible. Any assistance you and the Staff can
provide to the Companies to resolve these issues on an expedited basis would be
very much appreciated. If you have any questions or further comments, please
call the undersigned at 202.383.0698.

Sincerely,

/s/ Mary E. Thornton
Mary E. Thornton

cc: Joyce M. Pickholz, Esq.
    Robert S. Lamont, Jr., Esq.
    John E. Connolly, Jr., Esq.