0001193125-11-355327.txt : 20120611
0001193125-11-355327.hdr.sgml : 20120611
20111229132656
ACCESSION NUMBER: 0001193125-11-355327
CONFORMED SUBMISSION TYPE: CORRESP
PUBLIC DOCUMENT COUNT: 1
FILED AS OF DATE: 20111229
FILER:
COMPANY DATA:
COMPANY CONFORMED NAME: METLIFE INVESTORS VARIABLE ANNUITY ACCOUNT ONE
CENTRAL INDEX KEY: 0000815915
IRS NUMBER: 431236042
STATE OF INCORPORATION: MO
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: 949-223-5680
MAIL ADDRESS:
STREET 1: 5 PARK PLAZA, SUITE 1900
CITY: IRVINE
STATE: CA
ZIP: 92614
FORMER COMPANY:
FORMER CONFORMED NAME: COVA VARIABLE ANNUITY ACCOUNT ONE
DATE OF NAME CHANGE: 19960314
FORMER COMPANY:
FORMER CONFORMED NAME: XEROX VARIABLE ANNUITY ACCOUNT ONE
DATE OF NAME CHANGE: 19920703
FORMER COMPANY:
FORMER CONFORMED NAME: ACCOUNT FOR PERFORMANCE
DATE OF NAME CHANGE: 19880307
CORRESP
1
filename1.txt
FROM: Pitts, Patrice
SENT: Thursday, December 29, 2011 10:42 AM
TO: 'Oh, Min S.'
SUBJECT: Follow-up Responses for Class A Filings
IMPORTANCE: High
Thank you for your prompt attention to the responses to the follow-up comments
that you provided on December 23, 2011, on post-effective amendment number 27 to
the registration statement on Form N-4 for MetLife Investors Variable Annuity
Account One (File Nos. 333-54358/811-05200) and post-effective amendment number
27 to the registration statement on Form N-4 for First MetLife Investors
Variable Annuity Account One (File Nos. 333-96775/ 811-08306). (The variable
contracts described in those filings will be referred to in this e-mail as "MLI
Class A contracts" and "FMLI Class A contracts," respectively.) When we
discussed those responses on Tuesday, December 27, you recommended further
changes to the disclosure for the May 1, 2012 annual updates of the registration
statements for the MLI Class A contracts and the FMLI Class A contracts in
connection with two of the December 23 comments. For your convenience, I have
summarized our discussion and those recommended changes below.
1. Follow-up on comment #2 (MLI and FMLI)--The SEC staff agreed with the
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approach of incorporating the beginning and ending offering periods for the
various riders in the descriptions of rider charges in the "Expenses" and
"Living Benefits" sections of the prospectuses.
RESPONSE: No further action is needed on this item.
2. Follow-up on comment #4.a (MLI and FMLI) and 4.c (FMLI, but also applies to
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MLI)--The SEC staff acknowledged that the changes made on the revised pages are
----
responsive to its comments, and recommended that further changes be made to the
fee table in future post-effective amendment filings. More specifically, to make
clear that certain riders reflected in the main body of the fee table are no
longer available, include the "cut-off" dates (rather than the beginning date)
for rider availability.
RESPONSE: MLI and FMLI each acknowledge the follow-up comment and will revise
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the disclosure in the May 1, 2012 prospectus for the MLI and FMLI Class A
contracts (respectively) to include the "cut-off" dates for rider
availability to make clear that certain riders reflected in the main body of the
fee table are no longer available under those contracts.
3. Follow-up on comment #7.a (MLI) and #6.a (FMLI)--The SEC staff acknowledged
-----------------------------------------------
that the changes made on the revised pages are responsive to its comment, and
suggested that MLI and FMLI consider adding a statement to the effect that
transfers of account value to investment options that a selling firm does not
support will be counted for purposes of any transfer restrictions that apply
under Class A contracts elsewhere in the prospectus--e.g., in the general
discussion of transfers and in the discussion of transfer charges.
RESPONSE: MLI and FMLI each acknowledge the follow-up comment and will consider
---------
adding the statement elsewhere in the May 1, 2012 prospectus for the MLI and
FMLI Class A contracts (respectively) where transfers of account value and
transfer charges are discussed.
Thanks, again, for your prompt attention to this matter and your efforts to
permit MLI and FMLI to meet the deadline of having the post-effective amendments
for the MLI Class A contracts and the FMLI Class A contracts declared effective
December 30, 2011.
PATRICE M. PITTS | COUNSEL
SUTHERLAND ASBILL & BRENNAN LLP
1275 Pennsylvania Avenue NW | Washington, DC 20004-2415
202.383.0548 direct | 202.637.3593 facsimile
patrice.pitts@sutherland.com | www.sutherland.com
---------------------------- ------------------
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