0001193125-09-141415.txt : 20120705
0001193125-09-141415.hdr.sgml : 20120704
20090630121205
ACCESSION NUMBER: 0001193125-09-141415
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20090630
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: METLIFE INVESTORS USA SEPARATE ACCOUNT A
CENTRAL INDEX KEY: 0000356475
IRS NUMBER: 540696644
STATE OF INCORPORATION: DE
FISCAL YEAR END: 1231
FILING VALUES:
FORM TYPE: CORRESP
BUSINESS ADDRESS:
STREET 1: 5 PARK PLAZA, SUITE 1900
CITY: IRVINE
STATE: CA
ZIP: 92614
BUSINESS PHONE: 9492235680
MAIL ADDRESS:
STREET 1: 5 PARK PLAZA, SUITE 1900
CITY: IRVINE
STATE: CA
ZIP: 92614
FORMER COMPANY:
FORMER CONFORMED NAME: METLIFE INVESTORS SEPARATE ACCOUNT A
DATE OF NAME CHANGE: 20010314
FORMER COMPANY:
FORMER CONFORMED NAME: SECURITY FIRST LIFE SEPARATE ACCOUNT A
DATE OF NAME CHANGE: 19920703
CORRESP
1
filename1.txt
[SUTHERLAND ASBILL & BRENNAN LLP LETTERHEAD]
1275 Pennsylvania Avenue NW
Washington, D.C. 20004-2415
202.383.0100
fax 202.637.3593
www.sutherland.com
ATLANTA AUSTIN HOUSTON
NEW YORK TALLAHASEE WASHINGTON DC
W. THOMAS CONNER
DIRECT LINE: 202.383.0590
E-mail: thomas.conner@sutherland.com
June 30, 2009
Alison White, Esq.
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: METLIFE INVESTORS USA INSURANCE COMPANY
METLIFE INVESTORS USA SEPARATE ACCOUNT A
PRE-EFFECTIVE AMENDMENT ON FORM N-4/A
FILE NOS. 811-03365 AND 333-158514
FIRST METLIFE INVESTORS INSURANCE COMPANY
FIRST METLIFE INVESTORS VARIABLE ANNUITY ACCOUNT ONE
PRE-EFFECTIVE AMENDMENT ON FORM N-4/A
FILE NOS. 811-08306 AND 333-158579
Dear Ms. White:
On behalf of MetLife Investors USA Insurance Company ("MLI USA") and its
separate account, MetLife Investors USA Separate Account A, and First MetLife
Investors Insurance Company ("First MetLife Investors" and together with MLI
USA, "the Companies") and its separate account, First MetLife Investors Variable
Annuity Account One, we are providing the Companies responses to your additional
comments of June 29, 2009 in connection with the above-referenced Pre-Effective
Amendments filed on June 25, 2009. The Staff's additional comment is set forth
below, followed by the Companies response.
1. FEE TABLE--ADDITIONAL RIDER CHARGE (LIFETIME WITHDRAWAL GUARANTEE RIDER
CHARGES)
COMMENT: (a) Please switch the charge information appearing in the Lifetime
Withdrawal Guarantee (Single Life version and Joint Life version) so that the
maximum charge appears before the current charge. This change can be filed via
Rule 497 of the Securities Act of 1933, as amended.
Alison White, Esq.
June 30, 2009
Page 2
RESPONSE: (a) The Companies have switched the lines opposite the Lifetime
Withdrawal Guarantee (Single Life version and Joint Life version) so that the
maximum charge appears above the current charge. The revised pages are attached.
The Companies will file the revised prospectus via Rule 497 of the Securities
Act of 1993, as amended.
* * *
We hope you will find these responses satisfactory. If you have any questions or
comments, please contact the undersigned at (202) 383-0590 or Lisa Flanagan at
(202) 383-0873.
Sincerely,
/s/ W. Thomas Conner
-------------------------------------
W. Thomas Conner
cc: Michele H. Abate, Esq.
John R. Richards, Esq.
Lisa Flanagan, Esq.