CORRESP

                                                                  Reed Smith LLP
                                                   Riverfront Plaza - West Tower
                                                901 East Byrd Street, Suite 1700
                                                         Richmond, VA 23219-4068
                                                             Tel +1 804 344 3400
                                                             Fax +1 804 344 3410

                                                             1301 K Street, N.W.
                                                         Suite 1100 - East Tower
                                                     Washington, D.C. 20005-3373
W. THOMAS CONNER                                                 +1 202 414 9200
Direct Phone: +1 202 414 9208                                Fax +1 202 414 9299
Email: tconner@reedsmith.com
                                                                   reedsmith.com

June 25, 2015

BY ELECTRONIC MAIL AND EDGAR CORRESPONDENCE SUBMISSION

Sonny Oh
Securities and Exchange Commission
Division of Investment Management
100 F Street, NE
Washington, DC 20549

RE:  METLIFE INVESTORS USA SEPARATE ACCOUNT A
     SERIES O (OFFERED ON AND AFTER JULY __, 2015)
     INITIAL REGISTRATION STATEMENT FILED ON FORM N-4 ON APRIL 30, 2015
     FILE NOS. 811-03365 AND 333-203748

Dear Mr. Oh:

On behalf of MetLife Insurance Company USA ("MetLife USA") and its separate
account, MetLife Investors USA Separate Account A (the "Registrant"), we are
responding to the comments that the staff (the "staff") of the Securities and
Exchange Commission (the "Commission") provided to us by correspondence dated
June 25, 2015 with regard to the initial registration statement on Form N-4
(the "Registration Statement") relating to the Series O (offered on and after
July __, 2015) variable annuity contracts (the "Contracts").

For ease of reference, each of the comments of the staff is set forth below,
followed by MetLife USA's response. Unless noted otherwise, page references in
MetLife USA's responses are to the marked courtesy copies of the prospectus and
Statement of Additional Information ("SAI") provided to the staff in connection
with the filing of the Registration Statement. To the extent our responses
propose revised disclosure, we have attached hereto the corresponding pages
from the revised prospectus.

GENERAL
-------

1.   Please disclose to the staff whether there are any types of guarantees or
support agreements with any third parties.

     RESPONSE: There are no guarantees or support agreements with third parties.

  ABU DHABI o ATHENS o BEIJING o CENTURY CITY o CHICAGO o DUBAI o FRANKFURT o
 HONG KONG o HOUSTON o KAZAKHSTAN o LONDON o LOS ANGELES o MUNICH o NEW YORK o
NORTHERN VIRGINIA PARIS o PHILADELPHIA o PITTSBURGH o PRINCETON o RICHMOND o SAN
    FRANCISCO o SHANGHAI o SILICON VALLEY o SINGAPORE o WASHINGTON, D.C. o
                                  WILMINGTON



Sonny Oh                                                     [LOGO OF ReedSmith]
June 25, 2015
Page 2

2.   Please confirm that the date of the prospectus will be the same as or
about the date of effectiveness.

     RESPONSE: We confirm that the date of the prospectus will be the same as
     or about the date of effectiveness.

3.   Please confirm that the EDGAR series/class identifiers will appropriately
be revised prior to effectiveness of the registration statement.

     RESPONSE: We confirm that the EDGAR series/class identifiers will be
     appropriately revised prior to effectiveness to reflect the date on which
     MetLife USA commences offering the Contracts.

PROSPECTUS
----------

4.   GUARANTEED LIFETIME WITHDRAWAL BENEFIT (PAGE 38)

     In the paragraph preceding the Summary on page 39, please reconcile the
first sentence with Note 2 to the Additional Optional Rider Charges tables on
page 9.

     RESPONSE: The GLWB rider is now available in all states in which the
     Contracts will be offered. Accordingly, pursuant to the staff's comment,
     we have revised the first sentence in the paragraph preceding the Summary
     to delete the introductory clause, "[i]n states where approved," from that
     sentence.

5.   DEATH BENEFIT (PAGE 49)

     In the second paragraph under "Upon Your Death," please clarify whether
you are referring to versions of the death benefit riders.

     RESPONSE: Pursuant to the staff's comment, we have revised the first
     sentence of the second paragraph under "Upon Your Death" to read as
     follows: "There may be versions of each death benefit rider (i.e., the
     Principal Protection Death Benefit rider, the Annual Step-Up Death Benefit
     rider and the Additional Death Benefit -- Earnings Preservation Benefit
     rider) that vary by issue date and state availability."

6.   FEDERAL INCOME TAX STATUS (PAGE 53)

     Please confirm the section is current and accurate.

     RESPONSE: We confirm that this section is current and accurate.



Sonny Oh                                                     [LOGO OF ReedSmith]
June 25, 2015
Page 3

STATEMENT OF ADDITIONAL INFORMATION
-----------------------------------

7.   Based on the anticipated effective date for the filing, please confirm
that all information required as of the most recent fiscal or calendar year has
been updated appropriately, E.G., commission table on page 4.

     RESPONSE: We confirm that all information included in the SAI will meet
     the applicable requirements of Section 10(a)(3) of the Securities Act of
     1933 or Regulation S-X, as the case may be, and the requirements of Form
     N-4.

8.   FINANCIAL STATEMENTS, EXHIBITS, AND CERTAIN OTHER INFORMATION

Any financial statements, exhibits, and any other required disclosure not
included in this registration statement must be filed by pre-effective
amendment to the registration statement.

     RESPONSE: We confirm that the financial statements, exhibits and any other
     required disclosure that have not been included in the Registration
     Statement will be included in, and filed by, a pre-effective amendment to
     the Registration Statement.

9.   REPRESENTATIONS

     We urge all persons who are responsible for the accuracy and adequacy of
the disclosure in the filings reviewed by the staff to be certain that they
have provided all information investors require for an informed decision. Since
the registrant is in possession of all facts relating to the registrant's
disclosure, it is responsible for the accuracy and adequacy of the disclosures
it has made.

     Notwithstanding our comments, in the event the registrant requests
acceleration of the effective date of the pending registration statement, it
should furnish a letter, at the time of such request, acknowledging that

     o  should the Commission or the staff, acting pursuant to delegated
        authority, declare the filing effective, it does not foreclose the
        Commission from taking any action with respect to the filing;

     o  the action of the Commission or the staff, acting pursuant to delegated
        authority, in declaring the filing effective, does not relieve the
        registrant from its full responsibility for the adequacy and accuracy
        of the disclosure in the filing; and

     o  the registrant may not assert this action as a defense in any
        proceeding initiated by the Commission or any person under the federal
        securities laws of the United States.

     In addition, please be advised that the Division of Enforcement has access
to all information you provide to the staff of the Division of Investment
Management in connection with our review of your filing or in response to our
comments on your filing.



Sonny Oh                                                     [LOGO OF ReedSmith]
June 25, 2015
Page 4

     We will consider a written request for acceleration of the effective date
of the registration statement as a confirmation of the fact that those
requesting acceleration are aware of their respective responsibilities.

     RESPONSE: We will provide the requisite "Tandy representations" in
     subsequent correspondence requesting acceleration pursuant to Rule 461
     under the Securities Act.

                      *                *                *

We hope that you will find these responses satisfactory. If you have questions
or comments about this matter, please contact the undersigned at 202.414.9208
or Peggy Heminger at 412.288.7204.

Very truly yours,

/s/ W. Thomas Conner
-------------------------
W. Thomas Conner

WTC/PCH

Attachment

cc:   Peggy C. Heminger

CORRESP

are received from the appropriate regulator. We may also be required to provide
additional information about you and your contract to government regulators.




7. LIVING BENEFIT

GUARANTEED LIFETIME WITHDRAWAL BENEFIT


If you want to invest your Account Value in the Investment Portfolio(s) during
the Accumulation Phase, but also want to guarantee that you will receive
lifetime income regardless of investment performance (subject to the conditions
described in "Operation of the GLWB" below, including the condition that
withdrawals before the Lifetime Withdrawal Age or withdrawals that are Excess
Withdrawals will reduce the payments under the guarantee or, if such
withdrawals reduce the Account Value to zero, eliminate the guarantee), we
offer a rider for an additional charge, called the Guaranteed Lifetime
Withdrawal Benefit (GLWB).


The GLWB rider is designed to allow you to invest your Account Value in the
Investment Portfolios, while guaranteeing that you will receive lifetime income
regardless of investment performance, subject to the conditions described in
"Operation of the GLWB" below. You may begin taking withdrawals under the GLWB
rider immediately or at a later time; however, any withdrawals taken prior to
the Lifetime Withdrawal Age will reduce the Benefit Base (see "Managing Your
Withdrawals" below).



You may purchase the GLWB rider if you are at least age 50 and not older than
age 85 on the effective date of your contract. You may not select this rider
together with the optional Annual Step-Up Death Benefit or the optional
Earnings Preservation Benefit. Once selected, the GLWB rider may not be
terminated except as stated below.



SUMMARY OF THE GLWB


THE FOLLOWING SECTION PROVIDES A SUMMARY OF HOW THE GLWB RIDER WORKS. A MORE
DETAILED EXPLANATION OF THE OPERATION OF THE GLWB RIDER IS PROVIDED IN THE
SECTION BELOW CALLED "OPERATION OF THE GLWB."


The GLWB rider guarantees that you will receive lifetime income regardless of
investment performance, subject to the conditions described in "Operation of
the GLWB" below (including the condition that withdrawals before the Lifetime
Withdrawal Age or withdrawals that are Excess Withdrawals will reduce the
payments under the guarantee or, if such withdrawals reduce the Account Value
to zero, eliminate the guarantee). THE GLWB RIDER DOES NOT GUARANTEE LIFETIME
INCOME IF YOUR ACCOUNT VALUE IS REDUCED TO ZERO DUE TO A WITHDRAWAL PRIOR TO
THE LIFETIME WITHDRAWAL AGE OR A WITHDRAWAL THAT IS AN EXCESS WITHDRAWAL (SEE
"MANAGING YOUR WITHDRAWALS" BELOW).


Under the GLWB rider, we calculate a Benefit Base (the "Benefit Base") that
determines the maximum amount you may receive as withdrawals each Contract Year
after the Lifetime Withdrawal Age (the "Annual Benefit Payment") without
reducing your Benefit Base, and determines the amount of any lifetime payments
if the Account Value is reduced to zero. The Benefit Base is multiplied by the
applicable GLWB Withdrawal Rate while the Account Value is greater than zero to
determine your Annual Benefit Payment. The Benefit Base is multiplied by the
applicable GLWB Lifetime Guarantee Rate to determine your Annual Benefit
Payment if your Account Value is reduced to zero and lifetime payments are to
begin. The Benefit Base will be reduced for any withdrawal prior to the
Lifetime Withdrawal Age or any Excess Withdrawal (and any subsequent
withdrawals in the Contract Year that an Excess Withdrawal occurs). In any
event, withdrawals under the GLWB rider will reduce your Account Value and
death benefits.


IT IS IMPORTANT TO RECOGNIZE THAT THE BENEFIT BASE IS NOT AVAILABLE TO BE TAKEN
AS A LUMP SUM OR PAID AS A DEATH BENEFIT AND DOES NOT ESTABLISH OR GUARANTEE
YOUR ACCOUNT VALUE OR A MINIMUM RETURN FOR ANY INVESTMENT PORTFOLIO. However,
if you cancel the GLWB rider after a waiting period of at least ten (10) years
(the "Guaranteed Principal Adjustment Eligibility Date") the Guaranteed
Principal Adjustment will increase your Account Value to the Purchase Payments
credited within the first 120 days of the date that we issue the contract
reduced proportionately for any withdrawals, if greater than the Account Value
at the time of the cancellation. (See "Cancellation and Guaranteed Principal
Adjustment" below.)


While the GLWB rider is in effect, we may reject subsequent Purchase Payments
by sending advance written notice if any of the changes listed in the section
"Investment Allocation Restrictions for Certain Riders - Investment Allocation
and Other Purchase Payment Restrictions for the GLWB - Potential Restrictions
on Subsequent Purchase Payments" occur. Restrictions on subsequent Purchase
Payments will remain in effect until



                                       40





8. PERFORMANCE

We periodically advertise subaccount performance relating to the Investment
Portfolios. We will calculate performance by determining the percentage change
in the value of an Accumulation Unit by dividing the increase (decrease) for
that unit by the value of the Accumulation Unit at the beginning of the period.
This performance number reflects the deduction of the Separate Account product
charges (including certain death benefit rider charges) and the Investment
Portfolio expenses. It does not reflect the deduction of any applicable account
fee, sales charge, withdrawal charge, or applicable optional rider charges. The
deduction of these charges would reduce the percentage increase or make greater
any percentage decrease. Any advertisement will also include total return
figures which reflect the deduction of the Separate Account product charges
(including certain death benefit rider charges), account fee, sales charges,
withdrawal charges, applicable optional rider charges, and the Investment
Portfolio expenses. We will show performance that reflects both the maximum
sales charge (5.00% of the Purchase Payment) and the minimum sales charge
(1.00% of the Purchase Payment).


For periods starting prior to the date the contract was first offered, the
performance will be based on the historical performance of the corresponding
Investment Portfolios for the periods commencing from the date on which the
particular Investment Portfolio was made available through the Separate
Account.


In addition, the performance for the Investment Portfolios may be shown for the
period commencing from the inception date of the Investment Portfolios. These
figures should not be interpreted to reflect actual historical performance of
the Separate Account.


We may, from time to time, include in our advertising and sales materials
performance information for funds or investment accounts related to the
Investment Portfolios and/or their investment advisers or subadvisers. Such
related performance information also may reflect the deduction of certain
contract charges. We may also include in our advertising and sales materials
tax deferred compounding charts and other hypothetical illustrations, which may
include comparisons of currently taxable and tax deferred investment programs,
based on selected tax brackets.


We may advertise the living benefit and death benefit riders using
illustrations showing how the benefit works with historical performance of
specific Investment Portfolios or with a hypothetical rate of return (which
rate will not exceed 12%) or a combination of historical and hypothetical
returns. These illustrations will reflect the deduction of all applicable
charges including the portfolio expenses of the underlying Investment
Portfolios.


You should know that for any performance we illustrate, future performance will
vary and results shown are not necessarily representative of future results.




9. DEATH BENEFIT

UPON YOUR DEATH


If you die during the Accumulation Phase, we will pay a death benefit to your
Beneficiary (or Beneficiaries). The Principal Protection is the standard death
benefit for your contract. At the time you purchase the contract, depending on
availability in your state, you can select the optional Annual Step-Up Death
Benefit rider. You can also select the Additional Death Benefit -  Earnings
Preservation Benefit, either individually or with the Annual Step-Up Death
Benefit rider. If you have selected the optional Guaranteed Lifetime Withdrawal
Benefit (GLWB) living benefit rider, you may not select the Annual Step-Up
Death Benefit rider or the Earnings Preservation Benefit. You may select the
Annual Step-Up Death Benefit rider or the Earnings Preservation Benefit if you
are age 79 or younger at the effective date of your contract.



There may be versions of each death benefit rider (i.e., the Principal
Protection Death Benefit rider, the Annual Step-Up Death Benefit rider, and the
Additional Death Benefit - Earnings Preservation Benefit rider) that vary by
issue date and state availability. In addition, a version of a rider may become
available (or unavailable) in different states at different times. Please check
with your registered representative regarding which version(s) are available in
your state. If you have already been issued a contract, please check your
contract and riders for the specific provisions applicable to you.



The death benefit is determined as of the end of the Business Day on which we
receive both due proof of death and an election for the payment method. Until
the Beneficiary (or the first Beneficiary if there are multiple Beneficiaries)
submits the necessary documentation in Good Order, the Account Value
attributable to his/her portion of the death benefit remains in the Investment
Portfolios and is subject to investment risk.



                                       50