10-Q/A

UNITED STATES

SECURITIES AND EXCHANGE COMMISSION

Washington, D.C. 20549

FORM 10-Q/A

Amendment No. 1

(Mark One)

[X]  QUARTERLY REPORT PURSUANT TO SECTION 13 OR 15(D) OF THE SECURITIES EXCHANGE ACT OF 1934

For the quarterly period ended    June 30, 2011

[   ]  TRANSITION REPORT PURSUANT TO SECTION 13 OR 15(D) OF THE SECURITIES EXCHANGE ACT OF 1934

For the transition period from _________________ to _________________

Commission File Number: 333-65423

MONY Life Insurance Company of America

(Exact name of registrant as specified in its charter)

Arizona	86-0222062
(State or other jurisdiction of	(I.R.S. Employer
incorporation or organization)	Identification No.)

1290 Avenue of the Americas, New York, New York	10104
(Address of principal executive offices)	(Zip Code)

(212) 554-1234

(Registrant’s telephone number, including area code)

	Not applicable
(Former name, former address, and former fiscal year if changed since last report.)

Indicate by check mark whether the registrant (1) has filed all reports required to be filed by Section 13 or 15(d) of the Securities Exchange Act of 1934 during the preceding 12 months (or for such shorter period that the registrant was required to file such reports), and (2) has been subject to such filing requirements for the past 90 days.

Yes x No   o

Indicate by check mark whether the registrant has submitted electronically and posted on its corporate Web site, if any, every Interactive Data File required to be submitted and posted pursuant to Rule 405 of Regulation S-T (§232.405 of this chapter) during the preceding 12 months (or for such shorter period that the registrant was required to submit and post such files).

Yes x No o

Indicate by check mark whether the registrant is a large accelerated filer, an accelerated filer, a non-accelerated filer or a smaller reporting company.  See definition of “accelerated filer,” “large accelerated filer” and “smaller reporting company” in Rule 12b-2 of the Exchange Act.

Large accelerated filer  [   ]	Accelerated filer  [   ]
Non-accelerated filer    [X]  (Do not check if a smaller reporting company)	Smaller reporting company  [   ]

Indicate by check mark whether the registrant is a shell company (as defined in Rule 12b-2 of the Exchange Act).

Yes  [   ]    No  [X]

As of August 11, 2011, 2,500,000 shares of the registrant’s Common Stock were outstanding.

REDUCED DISCLOSURE FORMAT:

Registrant meets the conditions set forth in General Instruction H(1)(a) and (b) of Form 10-Q and is therefore filing this form with the reduced disclosure format

EXPLANATORY NOTE

The purpose of this Amendment No. 1 to our Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2011, as filed with the Securities and Exchange Commission on August 11, 2011 (the “Form 10-Q”), is to furnish the interactive data files as Exhibit 101 to the Form 10-Q.  Exhibit 101 to this Amendment No. 1 provides the following items from the Form 10-Q formatted in XBRL (Extensible Business Reporting Language):  (i) the balance sheets as of June 30, 2011 and December 31, 2010; (ii) the statements of earnings for the three-month and six-month periods ended June 30, 2011 and 2010; (iii) the statements of equity for the six-month periods ended June 30, 2011 and 2010, (iv)  the statements of cash flows for the six-month periods ended June 30, 2011 and 2010; and (iv) the notes to financial statements  as of June 30, 2011.

No changes have been made to the Form 10-Q other than as described above.  This Amendment No. 1 does not reflect any subsequent information or events occurring after the original filing date of the Form 10-Q or modify or update in any way disclosures made in the Form 10-Q, as filed with the Securities and Exchange Commission on August 11, 2011.

  2

PART II        OTHER INFORMATION

Item 6. Exhibits

Number	Description and Method of Filing
31.1	Certification of the registrant’s Chief Executive Officer, pursuant to Section 302 of the Sarbanes-Oxley Act of 2002
31.2	Certification of the registrant’s Chief Financial Officer, pursuant to Section 302 of the Sarbanes-Oxley Act of 2002
32.1	Certification of the registrant’s Chief Executive Officer, pursuant to Section 906 of the Sarbanes-Oxley Act of 2002
32.2	Certification of the registrant’s Chief Financial Officer, pursuant to Section 906 of the Sarbanes-Oxley Act of 2002
101.INS*	XBRL Instance Document
101.SCH*	XBRL Taxonomy Extension Schema Document
101.CAL*	XBRL Taxonomy Extension Calculation Linkbase Document
101.LAB*	XBRL Taxonomy Extension Label Linkbase Document
101.PRE*	XBRL Taxonomy Extension Presentation Linkbase Document
101.DEF*	XBRL Taxonomy Extension Definition Linkbase Document

* Furnished herewith.  All other exhibits were previously filed with MONY Life Insurance Company of America’s Quarterly Report on Form 10-Q for the quarterly period ended June 30, 2011 as filed with the Securities Exchange Commission on August 11, 2011.

  3

SIGNATURES

Pursuant to the requirements of the Securities Exchange Act of 1934, MONY Life Insurance Company of America has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized.

Date: August 25, 2011 MONY LIFE INSURANCE COMPANY OF AMERICA

		By:	/s/ Richard S. Dziadzio
			Name:		Richard S. Dziadzio
			Title:		Senior Executive Vice President and
					Chief Financial Officer
Date:	August 25, 2011		/s/ Alvin H. Fenichel
			Name:	Alvin H. Fenichel
			Title:	Senior Vice President and
				Chief Accounting Officer

4

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BALANCE SHEETS (Parentheticals) (USD $)	Jun. 30, 2011	Dec. 31, 2010
BALANCE SHEETS
Common Stock par value	$ 1	$ 1
Common Stock authorized	5,000,000	5,000,000
Common Stock issued	2,500,000	2,500,000
Common Stock outstanding	2,500,000	2,500,000

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STATEMENTS OF EARNINGS (LOSS) (USD $) In Millions	3 Months Ended		6 Months Ended
	Jun. 30, 2011	Jun. 30, 2010	Jun. 30, 2011	Jun. 30, 2010
REVENUES
Universal life and investment-type product policy fee income	$ 28	$ 31	$ 58	$ 62
Premiums	9	9	19	19
Net investment income (loss)	29	30	58	60
Investment gains (losses), net:
Total other-than-temporary impairment losses	(1)	(3)	(1)	(7)
Portion of loss recognized in other comprehensive income (loss)	0	0	0	1
Net impairment losses recognized	(1)	(3)	(1)	(6)
Other investment gains (losses), net	0	2	1	4
Total investment gains (losses), net	(1)	(1)	0	(2)
Other income	3	2	5	5
Increase (decrease) in fair value of reinsurance contracts	1	3	0	2
Total revenues	69	74	140	146
BENEFITS AND OTHER DEDUCTIONS
Policyholders benefits	20	19	47	49
Interest Credited To Policyholders Account Balances	13	16	28	34
Compensation and benefits	8	10	16	17
Commissions	11	8	20	17
Interest expense	0	1	0	1
Amortization of deferred policy acquisition costs and value of business acquired	7	11	(20)	25
Capitalization of deferred policy acquisition costs	(8)	(9)	(15)	(15)
Rent expense	1	1	2	2
Other operating costs and expenses	9	9	17	17
Total benefits and other deductions	61	66	95	147
Earnings (loss), before income taxes	8	8	45	(1)
Income tax (expense) benefit	(3)	(2)	3	2
Net Earnings (Loss)	$ 5	$ 6	$ 48	$ 1

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Document and Entity Information	6 Months Ended
	Jun. 30, 2011	Aug. 11, 2011
Document And Entity Information [Abstract]
Document Type	10-Q
Document Period End Date	Jun. 30, 2011
Document Fiscal Period Focus	Q2
Document Fiscal Year Focus	2011
Amendment Flag	false
Entity Registrant Name	MONY LIFE INSURANCE CO OF AMERICA
Entity Central Index Key	0000835357
Entity Current Reporting Status	Yes
Entity Voluntary Filers	No
Current Fiscal Year End Date	--12-31
Entity Filer Category	Non-accelerated Filer
Entity Well Known Seasoned Issuer	No
Entity Common Stock Shares Outstanding		2,500,000

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GMDB, GMIB AND NO LAPSE GUARANTEE FEATURES

6 Months Ended

Jun. 30, 2011

Gmdb Gmib And No Lapse Guarantee Features [Abstract]

GMDB GMIB AND NO LAPSE GUARANTEE FEATURES

6)       GMDB, GMIB AND NO LAPSE GUARANTEE FEATURES

A) Variable Annuity Contracts – GMDB and GMIB

MLOA has certain variable annuity contracts with GMDB and GMIB features in-force that guarantee one of the following:

• Return of Premium: the benefit is the greater of current account value or premiums paid (adjusted for withdrawals);
• Ratchet: the benefit is the greatest of current account value, premiums paid (adjusted for withdrawals), or the highest account value on any anniversary up to contractually specified ages (adjusted for withdrawals);
• Roll-Up: the benefit is the greater of current account value or premiums paid (adjusted for withdrawals) accumulated at contractually specified interest rates up to specified ages; or
• Combo: the benefit is the greater of the ratchet benefit or the roll-up benefit, which may include a five year or an annual reset.

The following table summarizes the GMDB and GMIB liabilities, before reinsurance ceded, reflected in the General Account in future policy benefits and other policyholders liabilities:

		GMDB		GMIB		Total
		(In Millions)
Balance at January 1, 2011		$	6	$	2	$	8
	Paid guarantee benefits		(1)		-		(1)
	Other changes in reserve		-		-		-
Balance at June 30, 2011		$	5	$	2	$	7
Balance at January 1, 2010		$	5	$	3	$	8
	Paid guarantee benefits		(1)		-		(1)
	Other changes in reserve		1		(1)		-
Balance at June 30, 2010		$	5	$	2	$	7

Related GMDB reinsurance ceded amounts were:

		Six Months Ended
		June 30,
		2011		2010
		(In Millions)
Balances, beginning of year		$	3	$	3
	Paid guarantee benefits		-		-
	Other changes in reserve		-		-
Balances, End of Period		$	3	$	3

The GMIB reinsurance contracts are considered derivatives and are reported at fair value.

The June 30, 2011 values for variable annuity contracts in-force on such date with GMDB and GMIB features are presented in the following table. For contracts with the GMDB feature, the net amount at risk in the event of death is the amount by which the GMDB benefits exceed related account values. For contracts with the GMIB feature, the net amount at risk in the event of annuitization is the amount by which the present value of the GMIB benefits exceeds related account values, taking into account the relationship between current annuity purchase rates and the GMIB guaranteed annuity purchase rates. Since variable annuity contracts with GMDB guarantees may also offer GMIB guarantees in the same contract, the GMDB and GMIB amounts listed are not mutually exclusive:

			Return
			of
			Premium		Ratchet		Roll-Up		Combo		Total
			(Dollars In Millions)
GMDB:
	Account values invested in:
		General Account	$	123	$	181		N/A	$	27	$	331
		Separate Accounts	$	399	$	504		N/A	$	86	$	989
	Net amount at risk, gross		$	5	$	59		N/A	$	16	$	80
	Net amount at risk, net of
		amounts reinsured	$	5	$	52		N/A	$	1	$	58
	Average attained age
		of contractholders		64.8		65.1		N/A		65.0		65.0
	Percentage of contractholders
		over age 70		23.5%		23.1%		N/A		20.1%		23.1%
	Contractually specified
		interest rates		N/A		N/A		N/A		5.0%		5.0%
GMIB:
	Account values invested in:
		General Account		N/A		N/A	$	27		N/A	$	27
		Separate Accounts		N/A		N/A	$	86		N/A	$	86
	Net amount at risk, gross			N/A		N/A	$	2		N/A	$	2
	Net amount at risk, net of
		amounts reinsured		N/A		N/A	$	-		N/A	$	-
	Weighted average years remaining
		until annuitization		N/A		N/A		2.0		N/A		2.0
	Contractually specified
		interest rates		N/A		N/A		5.0%		N/A		5.0%

B) Separate Account Investments by Investment Category Underlying GMDB and GMIB Features

The total account values of variable annuity contracts with GMDB and GMIB features include amounts allocated to the guaranteed interest option which is part of the General Account and variable investment options that invest through Separate Accounts in variable insurance trusts. The following table presents the aggregate fair value of assets, by major investment category, held by Separate Accounts that support variable annuity contracts with GMDB and GMIB benefits and guarantees. The investment performance of the assets impacts the related account values and, consequently, the net amount of risk associated with the GMDB and GMIB benefits and guarantees. Since variable annuity contracts with GMDB benefits and guarantees may also offer GMIB benefits and guarantees in each contract, the GMDB and GMIB amounts listed are not mutually exclusive:

Investment in Variable Insurance Trust Mutual Funds
		June 30,			December 31,
		2011			2010
		(In Millions)
GMDB:
	Equity	$	833	$	878
	Fixed income		100		111
	Balanced		18		18
	Other		38		46
	Total	$	989	$	1,053
GMIB:
	Equity	$	68	$	73
	Fixed income		14		15
	Other		4		6
	Total	$	86	$	94

C) Variable and Interest-Sensitive Life Insurance Policies - No Lapse Guarantee

The no lapse guarantee feature contained in variable and interest-sensitive life insurance policies keeps them in force in situations where the policy value is not sufficient to cover monthly charges then due. The no lapse guarantee remains in effect so long as the policy meets a contractually specified premium funding test and certain other requirements. At both June 30, 2011 and December 31, 2010, MLOA had liabilities of $1 million for no lapse guarantees reflected in the General Account in Future policy benefits and other policyholders liabilities.

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COMPREHENSIVE INCOME (LOSS)

6 Months Ended

Jun. 30, 2011

Comprehensive Income Loss [Abstract]

COMPREHENSIVE INCOME LOSS

• COMPREHENSIVE INCOME (LOSS)

The components of comprehensive income (loss) follow:

		Three Months Ended				Six Months Ended
		June 30,				June 30,
		2011		2010		2011			2010
		(In Millions)
Net earnings (loss)		$	5	$	6	$	48	$	1
Change in unrealized gains (losses), net of
	reclassification adjustment		10		23		2		33
Other comprehensive income (loss)			10		23		2		33
Comprehensive Income (Loss)		$	15	$	29	$	50	$	34

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ACCOUNTING CHANGES AND NEW ACCOUNTING PRONOUNCEMENTS

6 Months Ended

Jun. 30, 2011

New Accounting Pronouncements And Changes In Accounting Principles [Abstract]

ACCOUNTING CHANGES AND NEW ACCOUNTING PRONOUNCEMENTS

2)       ACCOUNTING CHANGES AND NEW ACCOUNTING PRONOUNCEMENTS

Accounting Changes

In January 2010, the FASB issued new guidance for improving disclosures about fair value measurements.  This guidance requires a reporting entity to disclose separately the amounts of significant transfers in and out of Level 1 and Level 2 fair value measurements and describe the reasons for the transfers. In addition, for Level 3 fair value measurements, a reporting entity should present separately information about purchases, sales, issuances and settlements.  This guidance was effective for interim and annual reporting periods ending on or after December 15, 2009 except for disclosures for Level 3 fair value measurements which was effective for the first quarter of 2011.  These new disclosures have been included in the Notes to MLOA's financial statements, as appropriate.

New Accounting Pronouncements

In June 2011, the FASB issued new guidance to amend the existing alternatives for presenting other comprehensive income and its components in financial statements. The amendments eliminate the current option to report other comprehensive income and its components in the statement of changes in equity. An entity can elect to present items of net income and other comprehensive income in one continuous statement or in two separate, but consecutive statements. This guidance will not change the items that constitute net income and other comprehensive income, when an item of other comprehensive income must be reclassified to net income. This guidance is effective for interim and annual periods beginning after December 15, 2011.Management does not expect that implementation of this guidance will have a material impact on MLOA's financial statements.

In May 2011, the FASB amended its guidance on fair value measurements and disclosure requirements to enhance comparability between U.S. GAAP and International Financial Reporting Standards (“IFRS”). The changes to the existing guidance include how and when the valuation premise of highest and best use applies, the application of premiums and discounts, as well as new required disclosures. This guidance is effective for reporting periods beginning after December 15, 2011, with early adoption prohibited. Management does not expect that implementation of this guidance will have a material impact on MLOA's financial statements.

In April 2011, the FASB issued new guidance for a creditor's determination of whether a restructuring is a troubled debt restructuring (“TDR”). The new guidance provides additional guidance to creditors for evaluating whether a modification or restructuring of a receivable is a TDR. The new guidance will require creditors to evaluate modifications and restructurings of receivables using a more principles-based approach, which may result in more modifications and restructurings being considered TDR. The financial reporting implications of being classified as a TDR are that the creditor is required to:

• Consider the receivable impaired when calculating the allowance for credit losses; and
• Provide additional disclosures about its troubled debt restructuring activities in accordance with the requirements of recently issued guidance on disclosures about the credit quality of financing receivables and the allowance for credit losses.

The new guidance is effective for the first interim or annual period beginning on or after June 15, 2011. Management does not expect that implementation of this guidance will have a material impact on MLOA's financial statements.

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SHARE-BASED AND OTHER COMPENSATION PROGRAMS

6 Months Ended

Jun. 30, 2011

Shared Based And Other Compensation Programs [Abstract]

SHARE BASED AND OTHER COMPENSATION PROGRAMS

8)        SHARE-BASED COMPENSATION

For the second quarter and first six months of 2011 and 2010, MLOA recognized compensation cost (credit) of $319,000, $854,000, $(47,000) and $843,000, respectively, for share-based payment arrangements.

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INCOME TAXES

6 Months Ended

Jun. 30, 2011

Income Taxes [Abstract]

INCOME TAXES

9)       INCOME TAXES

Income taxes for interim periods ended June 30, 2011 and 2010 have been computed using an estimated annual effective tax rate. This rate is revised, if necessary, at the end of each successive interim period to reflect the current estimate of the annual effective tax rate. The tax benefit for the six months ended June 30, 2011 reflected a benefit in the amount of $19 million related to the determination that the valuation allowance previously established on deferred tax assets related to net operating loss carry forwards was no longer necessary.

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RELATED PARTY TRANSACTIONS

6 Months Ended

Jun. 30, 2011

Related Party Transactions [Abstract]

RELATED PARTY TRANSACTIONS

7)        RELATED PARTY TRANSACTIONS

Under its service agreement with AXA Equitable, personnel services, employee benefits, facilities, supplies and equipment are provided to MLOA to conduct its business. The associated costs related to the service agreements are allocated to MLOA based on methods that management believes are reasonable, including a review of the nature of such costs and activities performed to support MLOA. As a result of such allocations, MLOA incurred expenses of $14 million, $26 million, $14 million and $25 million for the second quarter and first six monthsof 2011 and of 2010, respectively. At June 30, 2011 and December 31, 2010, MLOA reported a payable to AXA Equitable in connection with its service agreement of $12 million and $8 million, respectively.

Various AXA affiliates cede a portion of their life, health and catastrophe insurance business through reinsurance agreements to AXA Global Life (and AXA Cessions in 2009 and prior), AXA affiliated reinsurers. AXA Global Life, in turn, retrocedes a quota share portion of these risks to AXA Equitable and MLOA on a one-year term basis. Premiums earned in second quarter and first six months of 2011 and 2010 under this arrangement were $77,000, $117,000, $71,000 and $291,000, respectively. Claims and expenses paid in the second quarter and first six months of 2011 and 2010 were $113,000, $44,000, $146,000 and $174,000, respectively.

MLOA ceded new variable life policies on an excess of retention basis with AXA Equitable and reinsured the no lapse guarantee riders through AXA Financial (Bermuda) Ltd. MLOA reported $83,000, $166,000, $83,000 and $178,000 of ceded premiums for the second quarter and first six monthsof 2011 and of 2010, respectively.

In addition to the AXA Equitable service agreement, MLOA has various other service and investment advisory agreements with affiliates. The expenses incurred by MLOA related to these agreements were $480,000, $958,000, $501,000 and $1,003,000 for the second quarter and first six monthsof 2011 and of 2010, respectively.

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STATEMENT OF CASH FLOWS (USD $) In Millions	6 Months Ended
	Jun. 30, 2011	Jun. 30, 2010
STATEMENTS OF CASH FLOWS
Net Earnings (Loss)	$ 48	$ 1
Adjustments to reconcile net earnings (loss) to net cash provided by (used in) operating activities:
Interest credited to policyholders account balances	28	34
Universal life and investment-type product policy fee income	(58)	(62)
Investment (gains) losses, net	0	2
Change in deferred policy acquisition costs and value of business acquired	(35)	10
Change in accrued investment income	0	(1)
Change in fair value of reinsurance contracts	0	(2)
Change in future policy benefits	0	(4)
Change in other policyholders liabilities	(3)	(3)
Change in income taxes payable	(4)	(2)
Provision for depreciation and amortization	2	2
Dividend from AllianceBernstein	3	3
Other, net	0	0
Net cash provided by (used in) operating activities	(19)	(22)
Cash flows from investing activities:
Maturities and repayments of fixed maturities and mortgage loans	87	25
Sales of investments	6	57
Purchases of investments	(138)	(51)
Other, net	(4)	(4)
Net cash provided by (used in) investing activities	(49)	27
Cash flows from financing activities:
Deposits	62	110
Withdrawals and transfers to Separate Accounts	(62)	(114)
Repayment of loans from affiliates	0	(2)
Net cash provided by (used in) financing activities	0	(6)
Change in cash and cash equivalents	(68)	(1)
Cash and cash equivalents, beginning of year	92	57
Cash and Cash Equivalents, End of Period	24	56
Supplemental Cash Flow Information [Abstract]
Interest Paid	0	1
Schedule of non-cash financing activities:
Shared-based Programs	$ 0	$ 0

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INVESTMENTS

6 Months Ended

Jun. 30, 2011

Investments Disclosure [Abstract]

INVESTMENTS

3)       INVESTMENTS

Fixed Maturities and Equity Securities

The following table provides information relating to fixed maturities classified as AFS; no equity securities were classified as AFS:

Available-for-Sale Securities by Classification
					Gross		Gross
			Amortized		Unrealized		Unrealized		Fair		OTTI
			Cost		Gains		Losses		Value		in AOCI(3)
			(In Millions)
June 30, 2011:
Fixed Maturities:
	Corporate		$	1,602	$	125	$	3	$	1,724	$	-
	U.S. Treasury, government
		and agency		69		2		-		71		-
	States and political subdivisions			21		-		-		21		-
	Foreign governments			4		-		-		4		-
	Commercial mortgage-backed			64		1		30		35		2
	Residential mortgage-backed(1)			28		2		-		30		-
	Asset-backed(2)			9		1		-		10		-
	Redeemable preferred stock			81		-		2		79		-
Total at June 30, 2011			$	1,878	$	131	$	35	$	1,974	$	2
December 31, 2010:
Fixed Maturities:
	Corporate		$	1,522	$	112	$	5	$	1,629	$	-
	U.S. Treasury, government
		and agency		87		1		-		88		-
	States and political subdivisions			21		-		1		20		-
	Foreign governments			4		-		-		4		-
	Commercial mortgage-backed			68		-		32		36		3
	Residential mortgage-backed(1)			33		2		-		35		-
	Asset-backed(2)			10		1		-		11		-
	Redeemable preferred stock			81		-		4		77		-
Total at December 31, 2010			$	1,826	$	116	$	42	$	1,900	$	3

• Includes publicly traded agency pass-through securities and collateralized mortgage obligations.
• Includes credit-tranched securities collateralized by sub-prime mortgages and other asset types and credit tenant loans.
• Amounts represent OTTI losses in AOCI, which were not included in earnings (loss) in accordance with current accounting guidance.

The contractual maturities of AFS fixed maturities (excluding redeemable preferred stock) at June 30, 2011 are shown in the table below. Bonds not due at a single maturity date have been included in the table in the year of final maturity. Actual maturities may differ from contractual maturities because borrowers may have the right to call or prepay obligations with or without call or prepayment penalties.

Available-for-Sale Fixed Maturities
Contractual Maturities at June 30, 2011
		Amortized Cost		Fair Value
		(In Millions)
Due in one year or less		$	71	$	73
Due in years two through five			762		822
Due in years six through ten			723		777
Due after ten years			140		148
	Subtotal		1,696		1,820
Commercial mortgage-backed securities			64		35
Residential mortgage-backed securities			28		30
Asset-backed securities			9		10
Total		$	1,797	$	1,895

For the first sixmonths of 2011 and 2010, proceeds received on sales of fixed maturities classified as AFS amounted to $10 million and $21 million, respectively. Gross gains of $1 million and $1 million and gross losses of $1 million and $0 million were realized on these sales for the first six months of 2011 and 2010, respectively. The change in unrealized investment gains (losses) related to fixed maturities classified as AFS for the first six months of 2011 and 2010 amounted to $22 million and $61 million, respectively.

MLOA recognized OTTI on AFS fixed maturities as follows:

	Three Months Ended				Six Months Ended
	June 30,				June 30,
	2011		2010		2011		2010
	(In Millions)
Credit losses recognized in earnings (loss)	$	(1)	$	(3)	$	(1)	$	(6)
Non-credit losses recognized in OCI		-		-		-		(1)
Total OTTI	$	(1)	$	(3)	$	(1)	$	(7)

The following table sets forth the amount of credit loss impairments on fixed maturity securities held by MLOA at the dates indicated and the corresponding changes in such amounts.

	Fixed Maturities - Credit Loss Impairments
		Three Months Ended					Six Months Ended
		June 30,					June 30,
			2011		2010		2011		2010
			(In Millions)
Balances, beginning of period			$	(72)	$	(57)	$	(83)	$	(54)
Previously recognized impairments on securities that matured,
	paid, prepaid or sold			-		26		11		26
Recognized impairments on securities impaired to fair value this period(1)				-		-		-		-
Impairments recognized this period on securities not previously impaired				(1)		(2)		(1)		(5)
Additional impairments this period on securities previously impaired				-		(1)		-		(1)
Increases due to passage of time on previously recorded credit losses				-		-		-		-
Accretion of previously recognized impairments due to increases in
	expected cash flows			-		-		-		-
Balances at June 30,			$	(73)	$	(34)	$	(73)	$	(34)

(1)        Represents circumstances where MLOA determined in the current period that it intends to sell the security or it is more likely than not that it will be required to sell the security before recovery of the security's amortized cost.

Net unrealized investment gains (losses) on fixed maturities classified as AFS are included in the balance sheets as a component of AOCI. The table below presents these amounts as of the dates indicated:

			June 30,		December 31,
			2011		2010
			(In Millions)
AFS Securities:
	Fixed maturities:
		With OTTI loss	$	(3)	$	(3)
		All other		99		77
Net Unrealized Gains (Losses)			$	96	$	74

Changes in net unrealized investment gains (losses) recognized in AOCI include reclassification adjustments to reflect amounts realized in Net earnings (loss) for the current period that had been part of OCI in earlier periods. The tables that follow below present a rollforward of net unrealized investment gains (losses) recognized in AOCI, split between amounts related to fixed maturity securities on which an OTTI loss has been recognized, and all other:

Net Unrealized Gains (Losses) on Fixed Maturities with OTTI Losses
								AOCI Gain
		Net						(Loss) Related
		Unrealized				Deferred		to Net
		Gains				Income		Unrealized
		(Losses) on		DAC and		Tax Asset		Investment
		Investments		VOBA		(Liability)		Gains (Losses)
		(In Millions)
Balance, April 1, 2011		$	(2)	$	-	$	1	$	(1)
Net investment gains (losses) arising during the period			(1)		-		-		(1)
Reclassification adjustment for OTTI losses:
	Included in Net earnings (loss)		-		-		-		-
	Excluded from Net earnings (loss)(1)		-		-		-		-
Impact of net unrealized investment gains (losses) on:
	DAC and VOBA		-		-		-		-
	Deferred income taxes		-		-		-		-
Balance, June 30, 2011		$	(3)	$	-	$	1	$	(2)
Balance, April 1, 2010		$	(1)	$	1	$	-	$	-
Net investment gains (losses) arising during the period			2		-		-		2
Reclassification adjustment for OTTI losses:
	Included in Net earnings (loss)		(1)		-		-		(1)
	Excluded from Net earnings (loss)(1)		-		-		-		-
Impact of net unrealized investment gains (losses) on:
	DAC and VOBA		-		(1)		-		(1)
	Deferred income taxes		-		-		-		-
Balance, June 30, 2010		$	-	$	-	$	-	$	-

• Represents “transfers in” related to the portion of OTTI losses recognized during the period that were not recognized in earnings (loss) for securities with no prior OTTI loss.

								AOCI Gain
		Net						(Loss) Related
		Unrealized				Deferred		to Net
		Gains				Income		Unrealized
		(Losses) on		DAC and		Tax Asset		Investment
		Investments		VOBA		(Liability)		Gains (Losses)
		(In Millions)
Balance, January 1, 2011		$	(3)	$	-	$	1	$	(2)
Net investment gains (losses) arising during the period			-		-		-		-
Reclassification adjustment for OTTI losses:
	Included in Net earnings (loss)		-		-		-		-
	Excluded from Net earnings (loss)(1)		-		-		-		-
Impact of net unrealized investment gains (losses) on:
	DAC and VOBA		-		-		-		-
	Deferred income taxes		-		-		-		-
Balance, June 30, 2011		$	(3)	$	-	$	1	$	(2)
Balance, January 1, 2010		$	-	$	-	$	-	$	-
Net investment gains (losses) arising during the period			2		-		-		2
Reclassification adjustment for OTTI losses:
	Included in Net earnings (loss)		(1)		-		-		(1)
	Excluded from Net earnings (loss)(1)		(1)		-		-		(1)
Impact of net unrealized investment gains (losses) on:
	DAC and VOBA		-		-		-		-
	Deferred income taxes		-		-		-		-
Balance, June 30, 2010		$	-	$	-	$	-	$	-

• Represents “transfers in” related to the portion of OTTI losses recognized during the period that were not recognized in earnings (loss) for securities with no prior OTTI loss.

All Other Net Unrealized Investment Gains (Losses) in AOCI
								AOCI Gain
		Net						(Loss) Related
		Unrealized				Deferred		to Net
		Gains				Income		Unrealized
		(Losses) on		DAC and		Tax Asset		Investment
		Investments		VOBA		(Liability)		Gains (Losses)
		(In Millions)
Balance, April 1, 2011		$	77	$	(19)	$	(20)	$	38
Net investment gains (losses) arising during the period			23		-		-		23
Reclassification adjustment for OTTI losses:
	Included in Net earnings (loss)		(1)		-		-		(1)
	Excluded from Net earnings (loss)(1)		-		-		-		-
Impact of net unrealized investment gains (losses) on:
	DAC and VOBA		-		(5)		-		(5)
	Deferred income taxes		-		-		(6)		(6)
Balance, June 30, 2011		$	99	$	(24)	$	(26)	$	49
Balance, April 1, 2010		$	3	$	(3)	$	-	$	-
Net investment gains (losses) arising during the period			33		-		-		33
Reclassification adjustment for OTTI losses:
	Included in Net earnings (loss)		1		-		-		1
	Excluded from Net earnings (loss)(1)		-		-		-		-
Impact of net unrealized investment gains (losses) on:
	DAC and VOBA		-		1		-		1
	Deferred income taxes		-		-		(12)		(12)
Balance, June 30, 2010		$	37	$	(2)	$	(12)	$	23

• Represents “transfers out” related to the portion of OTTI losses recognized during the period that were not recognized in earnings (loss) for securities with no prior OTTI loss.

								AOCI Gain
		Net						(Loss) Related
		Unrealized				Deferred		to Net
		Gains				Income		Unrealized
		(Losses) on		DAC and		Tax Asset		Investment
		Investments		VOBA		(Liability)		Gains (Losses)
		(In Millions)
Balance, January 1, 2011		$	77	$	(6)	$	(24)	$	47
Net investment gains (losses) arising during the period			23		-		-		23
Reclassification adjustment for OTTI losses:
	Included in Net earnings (loss)		(1)		-		-		(1)
	Excluded from Net earnings (loss)(1)		-		-		-		-
Impact of net unrealized investment gains (losses) on:
	DAC and VOBA		-		(18)		-		(18)
	Deferred income taxes		-		-		(2)		(2)
Balance, June 30, 2011		$	99	$	(24)	$	(26)	$	49
Balance, January 1, 2010		$	(24)	$	7	$	6	$	(11)
Net investment gains (losses) arising during the period			57		-		-		57
Reclassification adjustment for OTTI losses:
	Included in Net earnings (loss)		3		-		-		3
	Excluded from Net earnings (loss)(1)		1		-		-		1
Impact of net unrealized investment gains (losses) on:
	DAC and VOBA		-		(9)		-		(9)
	Deferred income taxes		-		-		(18)		(18)
Balance, June 30, 2010		$	37	$	(2)	$	(12)	$	23

• Represents “transfers out” related to the portion of OTTI losses recognized during the period that were not recognized in earnings (loss) for securities with no prior OTTI loss.

The following tables disclose the fair values and gross unrealized losses of the 95 issues at June 30, 2011 and the 108 issues at December 31, 2010 of fixed maturities that are not deemed to be other-than-temporarily impaired, aggregated by investment category and length of time that individual securities have been in a continuous unrealized loss position for the specified periods at the dates indicated:

			Less Than 12 Months				12 Months or Longer				Total
					Gross				Gross				Gross
					Unrealized				Unrealized				Unrealized
			Fair Value		Losses		Fair Value		Losses		Fair Value		Losses
			(In Millions)
June 30, 2011:
Fixed Maturities:
Corporate			$	74	$	(2)	$	16	$	(1)	$	90	$	(3)
	U.S. Treasury, government
		and agency		3		-		-		-		3		-
	States and political subdivisions			18		-		-		-		18		-
	Foreign governments			2		-		-		-		2		-
	Commercial mortgage-backed			1		(2)		32		(28)		33		(30)
	Asset-backed			-		-		1		-		1		-
	Redeemable preferred stock			27		-		35		(2)		62		(2)
Total			$	125	$	(4)	$	84	$	(31)	$	209	$	(35)
December 31, 2010:
Fixed Maturities:
Corporate			$	87	$	(3)	$	30	$	(2)	$	117	$	(5)
	U.S. Treasury, government
		and agency		2		-		-		-		2		-
	States and political subdivisions			19		(1)		-		-		19		(1)
	Foreign governments			2		-		-		-		2		-
	Commercial mortgage-backed			1		(1)		32		(31)		33		(32)
	Asset-backed			-		-		1		-		1		-
	Redeemable preferred stock			-		-		70		(4)		70		(4)
Total			$	111	$	(5)	$	133	$	(37)	$	244	$	(42)

MLOA's investments in fixed maturity securities do not include concentrations of credit risk of any single issuer greater than 10% of the shareholder's equity of MLOA, other than securities of the U.S. government, U.S. government agencies and certain securities guaranteed by the U.S. government. MLOA maintains a diversified portfolio of corporate securities across industries and issuers and does not have exposure to any single issuer in excess of 1.2% of total investments. The largest exposures to a single issuer of corporate securities held at June 30, 2011 and December 31, 2010 were $27 million and $27 million, respectively. Corporate high yield securities, consisting primarily of public high yield bonds, are classified as other than investment grade by the various rating agencies, i.e., a rating below Baa3/BBB- or the NAIC designation of 3 (medium grade), 4 or 5 (below investment grade) or 6 (in or near default). At June 30, 2011 and December 31, 2010, respectively, approximately $164 million and $175 million, or 8.7% and 9.6%, of the $1,878 million and $1,826 million aggregate amortized cost of fixed maturities held by MLOA were considered to be other than investment grade. These securities had net unrealized losses of $27 million and $30 million at June 30, 2011 and December 31, 2010, respectively.

MLOA does not originate, purchase or warehouse residential mortgages and is not in the mortgage servicing business. MLOA's fixed maturity investment portfolio includes RMBS backed by subprime and Alt-A residential mortgages comprised of loans made by banks or mortgage lenders to residential borrowers with lower credit ratings. The criteria used to categorize such subprime borrowers include FICO scores, interest rates charged, debt-to-income ratios and loan-to-value ratios. Alt-A residential mortgages are mortgage loans where the risk profile falls between prime and subprime; borrowers typically have clean credit histories but the mortgage loan has an increased risk profile due to higher loan-to-value and debt-to-income ratios and/or inadequate documentation of the borrowers' income. At June 30, 2011 and December 31, 2010, MLOA owned $5 million and $5 million, respectively, in RMBS backed by subprime residential mortgage loans and no RMBS backed by Alt-A residential mortgage loans. RMBS backed by subprime and Alt-A residential mortgages are fixed income investments supporting General Account liabilities.

At June 30, 2011, the carrying value of fixed maturities which were non-income producing for the twelve months preceding that date was $2 million.

For the second quarter and first six months of 2011 and 2010, investment income is shown net of investment expenses of $1 million, $2 million, $1 million and $2 million, respectively.

Mortgage Loans

Mortgage loans on real estate are placed on nonaccrual status once management believes the collection of accrued interest is doubtful. Once mortgage loans on real estate are classified as nonaccrual loans, interest income is recognized under the cash basis of accounting and the resumption of the interest accrual would commence only after all past due interest has been collected or the mortgage loan on real estate has been restructured to where the collection of interest is considered likely. At June 30, 2011 and December 31, 2010, respectively, the carrying values of commercial and agricultural mortgage loans on real estate that had been classified as nonaccrual loans were $9 million and $9 million for commercial and $0 million and $0 million for agricultural, respectively.

Valuation Allowances for Mortgage Loans:

Allowances for credit losses for mortgage loans for the first six months of 2011 are as follows:

		Mortgage Loans
		Commercial		Agricultural		Total
		(In Millions)
Allowance for credit losses:
Beginning balance, January 1,		$	2	$	-	$	2
	Charge-offs		-		-		-
	Recoveries		-		-		-
	Provision		-		-		-
Ending Balance, June 30,		$	2	$	-	$	2
Ending Balance, June 30,:
	Individually Evaluated for Impairment	$	2	$	-	$	2
	Collectively Evaluated for Impairment	$	-	$	-	$	-
	Loans Acquired with Deteriorated Credit Quality	$	-	$	-	$	-

Investment valuation allowances for mortgage loans totaled $2 million at June 30, 2010.

The values used in these ratio calculations were developed as part of the periodic review of the commercial and agricultural mortgage loan portfolio, which includes an evaluation of the underlying collateral value. The following table provides information relating to the debt service coverage ratio for commercial and agricultural mortgage loans at June 30, 2011.

Mortgage Loans by Loan-to-Value and Debt Service Coverage Ratios
June 30, 2011
		Debt Service Coverage Ratio
												Less		Total
		Greater		1.8x to		1.5x to		1.2x to		1.0x to		than		Mortgage
Loan-to-Value Ratio:(2)		than 2.0x		2.0x		1.8x		1.5x		1.2x		1.0x		Loans
		(In Millions)
Commercial Mortgage Loans(1)
0% - 50%		$	5	$	-	$	-	$	-	$	2	$	-	$	7
50% - 70%			-		-		17		20		-		-		37
70% - 90%			-		-		-		-		27		-		27
90% plus			10		-		-		-		-		-		10
Total Commercial
	Mortgage Loans	$	15	$	-	$	17	$	20	$	29	$	-	$	81
Agricultural Mortgage Loans(1)
0% - 50%		$	2	$	-	$	6	$	10	$	1	$	23	$	42
50% - 70%			1		-		1		2		4		3		11
70% - 90%			-		-		-		-		-		-		-
90% plus			-		-		-		-		-		-		-
Total Agricultural
	Mortgage Loans	$	3	$	-	$	7	$	12	$	5	$	26	$	53
Total Mortgage Loans(1)
0% - 50%		$	7	$	-	$	6	$	10	$	3	$	23	$	49
50% - 70%			1		-		18		22		4		3		48
70% - 90%			-		-		-		-		27		-		27
90% plus			10		-		-		-		-		-		10
Total Mortgage Loans		$	18	$	-	$	24	$	32	$	34	$	26	$	134

• The debt service coverage ratio is calculated using the most recently reported net operating income results from property operations divided by annual debt service.
• The loan-to-value ratio is derived from current loan balance divided by the fair market value of the property. The fair market value of the underlying commercial properties is updated annually.

The following table provides information relating to the age analysis of past due mortgage loans at June 30, 2011.

Age Analysis of Past Due Mortgage Loans
														Recorded
														Investment
												Total		> 90 Days
		30-59		60-89		90 Days						Financing		and
		Days		Days		or >		Total		Current		Receivables		Accruing
								(In Millions)
	Commercial	$	-	$	-	$	-	$	-	$	81	$	81	$	-
	Agricultural		-		-		-		-		53		53		-
Total Mortgage Loans		$	-	$	-	$	-	$	-	$	134	$	134	$	-

The following table provides information relating to impaired mortgage loans at June 30, 2011 and December 31, 2010, respectively.

Impaired Mortgage Loans
				Unpaid				Average		Interest
		Recorded		Principal		Related		Recorded		Income
		Investment		Balance		Allowance		Investment(1)		Recognized
		(In Millions)
June 30, 2011:
With no related allowance recorded:
	Commercial mortgage loans - other	$	-	$	-	$	-	$	-	$	-
	Agricultural mortgage loans		-		-		-		-		-
Total		$	-	$	-	$	-	$	-	$	-
With related allowance recorded:
	Commercial mortgage loans - other	$	10	$	8	$	(2)	$	10	$	-
	Agricultural mortgage loans		-		-		-		-		-
Total		$	10	$	8	$	(2)	$	10	$	-
December 31, 2010:
With no related allowance recorded:
	Commercial mortgage loans - other	$	-	$	-	$	-	$	-	$	-
	Agricultural mortgage loans		-		-		-		-		-
Total		$	-	$	-	$	-	$	-	$	-
With related allowance recorded:
	Commercial mortgage loans - other	$	10	$	8	$	(2)	$	10	$	1
	Agricultural mortgage loans		-		-		-		-		-
Total		$	10	$	8	$	(2)	$	10	$	1

(1)       Represents a five-quarter average of recorded amortized cost.

Equity Investments

The following table presents MLOA's investment in 2.6 million units in AllianceBernstein, an affiliate, which is included in Other invested assets:

	Six Months Ended
	June 30,
	2011		2010
	(In Millions)
Balances, beginning of year	$	76	$	78
Equity in net earnings (loss)		2		2
Dividends received		(3)		(3)
Balances, End of period	$	75	$	77

MLOA holds equity in limited partnership interests and other equity method investments that primarily invest in securities considered to be other than investment grade. The carrying values of June 30, 2011 and December 31, 2010 were $2 million and $2 million, respectively.

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VALUE OF BUSINESS ACQUIRED (VOBA)

6 Months Ended

Jun. 30, 2011

Value Of Business Acquired [Abstract]

Value Of Business Acquired [Text Block]

4)        VALUE OF BUSINESS ACQUIRED

The following table presents MLOA's VOBA asset as of June 30, 2011 and December 31, 2010:

	Gross		Accumulated
	Carrying		Amortization
	Amount		and Other(1)		Net
	(In Millions)
VOBA
June 30, 2011	$	416	$	(316)	$	100
December 31, 2010	$	416	$	(309)	$	107

• Includes reactivity to unrealized investment gains (losses) and the impact of the December 31, 2005 MODCO recapture.

For the second quarter of 2011 amortization expense related to VOBA was $4 million and for the first six months of 2011 negative amortization expense related to VOBA was $10 million. For the second quarter and first six months of 2010 amortization expense was $7million and $18 million, respectively.VOBA amortization is estimated to range between $12 million and $8 million annually through 2015.

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FAIR VALUE DISCLOSURES

6 Months Ended

Jun. 30, 2011

Fair Value Disclosures [Abstract]

FAIR VALUE DISCLOSURES

5)        FAIR VALUE DISCLOSURES

Fair value is defined as the exchange price that would be received for an asset or paid to transfer a liability (an exit price) in the principal or most advantageous market for the asset or liability in an orderly transaction between market participants on the measurement date. The accounting guidance established a fair value hierarchy that requires an entity to maximize the use of observable inputs and minimize the use of unobservable inputs when measuring fair value, and identifies three levels of inputs that may be used to measure fair value:

Level 1       Quoted prices for identical instruments in active markets. Level 1 fair values generally are supported by market transactions that occur with sufficient frequency and volume to provide pricing information on an ongoing basis.

Level 2       Observable inputs other than Level 1 prices, such as quoted prices for similar instruments, quoted prices in markets that are not active, and inputs to model-derived valuations that are directly observable or can be corroborated by observable market data.

Level 3        Unobservable inputs supported by little or no market activity and often requiring significant management judgment or estimation, such as an entity's own assumptions about the cash flows or other significant components of value that market participants would use in pricing the asset or liability.

MLOA defines fair value as the quoted market prices for those instruments that are actively traded in financial markets. In cases where quoted market prices are not available, fair values are measured using present value or other valuation techniques. The fair value determinations are made at a specific point in time, based on available market information and judgments about the financial instrument, including estimates of the timing and amount of expected future cash flows and the credit standing of counterparties. Such adjustments do not reflect any premium or discount that could result from offering for sale at one time MLOA's entire holdings of a particular financial instrument, nor do they consider the tax impact of the realization of unrealized gains or losses. In many cases, the fair values cannot be substantiated by comparison to independent markets, nor can the disclosed value be realized in immediate settlement of the instrument.

Assets measured at fair value on a recurring basis are summarized below:

Fair Value Measurements
				Level 1		Level 2		Level 3		Total
				(In Millions)
June 30, 2011:
Assets:
Investments:
	Fixed maturities, available-for-sale:
		Corporate		$	-	$	1,706	$	18	$	1,724
		U.S. Treasury, government and agency			-		70		-		70
		States and political subdivisions			-		21		-		21
		Foreign governments			-		4		-		4
		Commercial mortgage-backed			-		-		35		35
		Residential mortgage-backed(1)			-		30		-		30
		Asset-backed(2)			-		5		6		11
		Redeemable preferred stock			19		60		-		79
			Subtotal		19		1,896		59		1,974
	Other equity investments				1		-		-		1
Cash equivalents					20		-		-		20
GMIB reinsurance contracts					-		-		2		2
Separate Accounts' assets					1,790		15		-		1,805
		Total Assets		$	1,830	$	1,911	$	61	$	3,802
December 31, 2010:
Assets:
Investments:
	Fixed maturities, available-for-sale:
		Corporate		$	-	$	1,610	$	19	$	1,629
		U.S. Treasury, government and agency			-		88		-		88
		States and political subdivisions			-		20		-		20
		Foreign governments			-		4		-		4
		Commercial mortgage-backed			-		-		36		36
		Residential mortgage-backed(1)			-		35		-		35
		Asset-backed(2)			-		6		5		11
		Redeemable preferred stock			19		58		-		77
			Subtotal		19		1,821		60		1,900
	Other equity investments				1		-		-		1
Cash equivalents					87		-		-		87
GMIB reinsurance contracts					-		-		2		2
Separate Accounts' assets					1,825		15		-		1,840
		Total Assets		$	1,932	$	1,836	$	62	$	3,830

(1)       Includes publicly traded agency pass-through securities and collateralized obligations.

(2)       Includes credit-tranched securities collateralized by sub-prime mortgages and other asset types and credit tenant loans.

At June 30, 2011 and December 31, 2010, respectively, investments classified as Level 1 comprise approximately 48.2% and 50.5% of invested assets measured at fair value on a recurring basis and primarily include redeemable preferred stock, cash equivalents and Separate Accounts assets. Fair value measurements classified as Level 1 include exchange-traded prices of fixed maturities, equity securities and net asset values for transacting subscriptions and redemptions of mutual fund shares held by Separate Accounts. Cash equivalents classified as Level 1 include money market accounts, overnight commercial paper and highly liquid debt instruments purchased with an original maturity of three months or less, and are carried at cost as a proxy for fair value measurement due to their short-term nature.

At June 30, 2011 and December 31, 2010, respectively, investments classified as Level 2 comprise approximately 50.3% and 47.9% of invested assets measured at fair value on a recurring basis and primarily include U.S. government and agency securities and certain corporate debt securities, such as private fixed maturities. As market quotes generally are not readily available or accessible for these securities, their fair value measures are determined utilizing relevant information generated by market transactions involving comparable securities and often are based on model pricing techniques that effectively discount prospective cash flows to present value using appropriate sector-adjusted credit spreads commensurate with the security's duration, also taking into consideration issuer-specific credit quality and liquidity. These valuation methodologies have been studied and evaluated by MLOA and the resulting prices determined to be representative of exit values.

Observable inputs generally used to measure the fair value of securities classified as Level 2 include benchmark yields, reported secondary trades, broker-dealer quotes, issuer spreads, benchmark securities, bids, offers, and reference data. Additional observable inputs are used when available, and as may be appropriate, for certain security types, such as prepayment, default, and collateral information for the purpose of measuring the fair value of mortgage- and asset-backed securities. At June 30, 2011 and December 31, 2010, respectively, approximately $31 million and $35 million of AAA-rated mortgage- and asset-backed securities are classified as Level 2, including CMBS, for which the observability of market inputs to their pricing models is supported by sufficient, albeit more recently contracted, market activity in these sectors.

At June 30, 2011 and December 31, 2010, respectively, investments classified as Level 3 comprise approximately 1.5% and 1.6% of invested assets measured at fair value on a recurring basis and primarily include corporate debt securities. Determinations to classify fair value measures within Level 3 of the valuation hierarchy generally are based upon the significance of the unobservable factors to the overall fair value measurement. Included in the Level 3 classification at June 30, 2011 and December 31, 2010, respectively, were approximately $5 million and $18 million of fixed maturities with indicative pricing obtained from brokers that otherwise could not be corroborated to market observable data. MLOA applies various due-diligence procedures, as considered appropriate, to validate these non-binding broker quotes for reasonableness, based on its understanding of the markets, including use of internally-developed assumptions about inputs a market participant would use to price the security. In addition, approximately $41 million and $42 million of mortgage- and asset-backed securities, including CMBS, are classified as Level 3 at June 30, 2011 and December 31, 2010, respectively. At June 30, 2011, MLOA continued to apply a risk-adjusted present value technique to estimate the fair value of CMBS securities below the senior AAA tranche due to ongoing insufficient frequency and volume of observable trading activity in these securities.  In applying this valuation methodology, MLOA adjusted the projected cash flows of these securities for origination year, default metrics, and level of subordination, with the objective of maximizing observable inputs, and weighted the result with a 10% attribution to pricing sourced from a third party service whose process placed significant reliance on market trading activity.

Level 3 also includes the GMIB reinsurance asset which is accounted for as a derivative contract. The GMIB reinsurance asset's fair value reflects the present value of reinsurance premiums and recoveries and risk margins over a range of market consistent economic scenarios. The valuation of the GMIB asset incorporates significant non-observable assumptions related to policyholder behavior, risk margins and projections of equity Separate Account funds consistent with the S&P 500 Index. Incremental adjustment is made to the resulting fair values of the GMIB asset to reflect changes in the claims-paying ratings of counterparties to the reinsurance treaties and of MLOA, respectively. After giving consideration to collateral arrangements, MLOA made no adjustment to reduce the fair value of its GMIB asset at June 30, 2011 to recognize incremental counterparty non-performance risk.

In the first six months of 2011, no AFS fixed maturities were transferred between levels.

In the first six months 2010, AFS fixed maturities with fair values of $9 million and $1 million were transferred out of Level 3 and into Level 2 and out of Level 2 and into Level 1, respectively, principally due to the availability of trading activity and/or market observable inputs to measure and validate their fair values. In addition, AFS fixed maturities with fair value of $2 million were transferred into the Level 3 classification. These transfers in the aggregate represent approximately 2% of total equity at June 30, 2010.

The table below presents a reconciliation for all Level 3 assets for second quarter and the first six months of 2011 and 2010 respectively:

Level 3 Instruments
Fair Value Measurements
							Commercial				Redeemable		GMIB
							Mortgage-		Asset-		Preferred		Reinsurance
					Corporate		backed		backed		Stock		Contracts
					(In Millions)
Balance, April 1, 2011					$	19	$	36	$	6	$	-	$	1
Total gains (losses), realized and
	unrealized included in:
	Earnings (loss) as:
		Net investment income (loss)				-		-		-		-		-
		Investment gains (losses), net				-		(1)		-		-		-
		Increase (decrease) in the fair value
			of the reinsurance contracts			-		-		-		-		1
				Subtotal		-		(1)		-		-		1
	Other comprehensive income (loss)					(1)		-		-		-		-
Purchases						-		-		-		-		-
Issuances						-		-		-		-		-
Sales						-		-		-		-		-
Settlements						-		-		-		-		-
Transfers into Level 3(2)						-		-		-		-		-
Transfers out of Level 3(2)						-		-		-		-		-
Balance, June 30, 2011					$	18	$	35	$	6	$	-	$	2
Balance, April 1, 2010					$	22	$	50	$	6	$	5	$	1
Total gains (losses), realized and
	unrealized included in:
	Earnings (loss) as:
		Net investment income (loss)				-		-		-		-		-
		Investment gains (losses), net				-		(3)		-		2		-
		Increase (decrease) in the fair value
			of the reinsurance contracts			-		-		-		-		2
				Subtotal		-		(3)		-		2		2
		Other comprehensive income (loss)				1		(4)		-		-		-
Purchases/issuances						-		-		-		-		1
Sales/settlements						-		-		-		(7)		-
Transfers into/out of Level 3(2)						(2)		-		-		-		-
Balance, June 30, 2010					$	21	$	43	$	6	$	-	$	4

• There were no U.S. Treasury, government and agency; State and political subdivisions; Foreign government; Residential mortgaged-backed securities; Other equity investments; Other invested assets or Separate Accounts' assets classified as Level 3 at June 30, 2011 and 2010.
• Transfers into/out of Level 3 classification are reflected at beginning-of-period fair values.

							Commercial				Redeemable		GMIB
							Mortgage-		Asset-		Preferred		Reinsurance
					Corporate		backed		backed		Stock		Contracts
					(In Millions)
Balance, January 1, 2011					$	19	$	36	$	5	$	-	$	2
Total gains (losses), realized and
	unrealized included in:
	Earnings (loss) as:
		Net investment income (loss)				-		-		-		-		-
		Investment gains (losses), net				-		-		1		-		-
		Increase (decrease) in the fair value
			of the reinsurance contracts			-		-		-		-		-
				Subtotal		-		-		1		-		-
	Other comprehensive income (loss)					(1)		2		-		-		-
Purchases						-		-		-		-		-
Issuances						-		-		-		-		-
Sales						-		(3)		-		-		-
Settlements						-		-		-		-		-
Transfers into Level 3(2)						-		-		-		-		-
Transfers out of Level 3(2)						-		-		-		-		-
Balance, June 30, 2011					$	18	$	35	$	6	$	-	$	2
Balance, January 1, 2010					$	24	$	64	$	6	$	5	$	2
Total gains (losses), realized and
	unrealized included in:
	Earnings (loss) as:
		Net investment income (loss)				-		-		-		-		-
		Investment gains (losses), net				-		(6)		-		2		-
		Increase (decrease) in the fair value
			of the reinsurance contracts			-		-		-		-		2
				Subtotal		-		(6)		-		2		2
		Other comprehensive income (loss)				1		(15)		-		-
Purchases/issuances						5		-		-		-		-
Sales/settlements						(2)		-		-		(7)		-
Transfers into/out of Level 3(2)						(7)		-		-		-		-
Balance, June 30, 2010					$	21	$	43	$	6	$	-	$	4

• There were no U.S. Treasury, government and agency; State and political subdivisions; Foreign government; Residential mortgaged-backed securities; Other equity investments; Other invested assets or Separate Accounts' assets classified as Level 3 at June 30, 2011 and 2010.
• Transfers into/out of Level 3 classification are reflected at beginning-of-period fair values.

The table below details changes in unrealized gains (losses) for the second quarter and first six monthsof 2011 and 2010 by category for Level 3 assets still held at June 30, 2011 and 2010, respectively:

					Earnings (Loss)
									Increase
					Net		Investment		(Decrease) in
					Investment		Gains		Fair Value of
					Income		(Losses),		Reinsurance
					(Loss)		Net		Contracts		OCI
					(In Millions)
Level 3 Instruments:
Second Quarter 2011
Still Held at June 30, 2011:(1)
	Change in unrealized gains (losses):
		Fixed maturities, available-for-sale:
			Commercial mortgage-backed		$	-	$	-	$	-	$	-
			Other fixed maturities, available-for-sale			-		-		-		(1)
				Subtotal		-		-		-		(1)
		GMIB reinsurance contracts				-		-		1		-
				Total	$	-	$	-	$	1	$	(1)
Second Quarter 2010
Still Held at June 30, 2010:(1)
	Change in unrealized gains (losses):
		Fixed maturities, available-for-sale:
			Corporate		$	-	$	-	$	-	$	1
			Commercial mortgage-backed			-		-		-		(4)
			Other fixed maturities, available-for-sale			-		-		-		-
				Subtotal		-		-		-		(4)
		GMIB reinsurance contracts				-		-		3		-
				Total	$	-	$	-	$	3	$	(4)

(1)       There were no Equity securities classified as AFS, Other equity investments, Cash equivalents and Separate Accounts' assets at June 30, 2011 and 2010.

					Earnings (Loss)
									Increase
					Net		Investment		(Decrease) in
					Investment		Gains		Fair Value of
					Income		(Losses),		Reinsurance
					(Loss)		Net		Contracts		OCI
					(In Millions)
Level 3 Instruments:
First Six Months of 2011
Still Held at June 30, 2011:(1)
	Change in unrealized gains (losses):
		Fixed maturities, available-for-sale:
			Commercial mortgage-backed		$	-	$	-	$	-	$	1
			Other fixed maturities, available-for-sale			-		-		-		(1)
				Subtotal		-		-		-		-
		GMIB reinsurance contracts				-		-		-		-
				Total	$	-	$	-	$	-	$	-
First Six Months of 2010
Still Held at June 30, 2010:(1)
	Change in unrealized gains (losses):
		Fixed maturities, available-for-sale:
			Corporate		$	-	$	-	$	-	$	1
			Commercial mortgage-backed			-		-		-		(15)
			Other fixed maturities, available-for-sale			-		-		-		-
				Subtotal		-		-		-		(14)
		GMIB reinsurance contracts				-		-		2		-
				Total	$	-	$	-	$	2	$	(14)

(1)       There were no Equity securities classified as AFS, Other equity investments, Cash equivalents, and Separate Accounts' assets at June 30, 2011 and 2010.

Fair value measurements are required on a non-recurring basis for certain assets, including goodwill, mortgage loans on real estate, equity real estate held for production of income, and equity real estate held for sale, only when an OTTI or other event occurs. When such fair value measurements are recorded, they must be classified and disclosed within the fair value hierarchy. At June 30, 2011 and December 31, 2010, no assets were required to be measured at fair value on a non-recurring basis.

The carrying values and fair values at June 30, 2011 and December 31, 2010 for financial instruments not otherwise disclosed in Note 3 are presented in the table below. Certain financial instruments are exempt from the requirements for fair value disclosure, such as insurance liabilities other than financial guarantees and investment contracts.

	June 30, 2011				December 31, 2010
	Carrying		Fair		Carrying		Fair
	Value		Value		Value		Value
	(In Millions)
Mortgage loans on real estate	$	132	$	138	$	141	$	146
Policyholders liabilities - Investment contracts		247		253		268		273

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STATEMENTS OF EQUITY (USD $) In Millions	Total	Total Shareholders Equity	Common Stock	Additional Paid-in Capital	Retained Earnings	Accumulated Other Comprehensive Income (Loss)
Beginning of year at Dec. 31, 2009			$ 2	$ 512	$ 67	$ (11)
Net Earnings (Loss)	1				1
Other comprehensive income (loss)						33
End of period at Jun. 30, 2010		604	2	512	68	22
Beginning of year at Dec. 31, 2010	605		2	514	44	45
Net Earnings (Loss)	48				48
Other comprehensive income (loss)						2
End of period at Jun. 30, 2011	$ 655	$ 655	$ 2	$ 514	$ 92	$ 47

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ORGANIZATION

6 Months Ended

Jun. 30, 2011

Organization [Abstract]

ORGANIZATION

MONY LIFE INSURANCE COMPANY OF AMERICA

NOTES TO FINANCIAL STATEMENTS

(UNAUDITED)

1)       BASIS OF PRESENTATION

The preparation of the accompanying unaudited financial statements in conformity with accounting principles generally accepted in the United States of America (“U.S. GAAP”) requires management to make estimates and assumptions (including normal, recurring accruals) that affect the reported amounts of assets and liabilities and the disclosure of contingent assets and liabilities at the date of the financial statements and the reported amounts of revenues and expenses during the reporting periods. Actual results could differ from these estimates. The accompanying unaudited interim financial statements reflect all adjustments necessary in the opinion of management for a fair presentation of the financial position of MLOA and its results of operations and cash flows for the periods presented. These statements should be read in conjunction with the audited financial statements of MLOA for the year ended December 31, 2010. The results of operations for the six months ended June 30, 2011 are not necessarily indicative of the results to be expected for the full year.

The terms “second quarter 2011” and “second quarter 2010” refer to the three months ended June 30, 2011 and 2010, respectively. The terms “first six months of 2011” and “first six months of 2010” refer to the six months ended June 30, 2011 and 2010, respectively.

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LITIGATION

6 Months Ended

Jun. 30, 2011

Litigation [Abstract]

LITIGATION

10)       LITIGATION

There have been no new material legal proceedings and no material developments in specific litigations previously reported in MLOA's Notes to Financial Statements for the year ended December 31, 2010, except as set forth below:

Insurance Regulatory Matters

MLOA, along with other life insurance industry companies, has been the subject of various examinations regarding its unclaimed property and escheatment procedures. For example, MLOA has been contacted by a third party auditor on behalf of a number of U.S. state jurisdictions for compliance with unclaimed property laws of those jurisdictions. MLOA is cooperating with these examinations.

A number of lawsuits have been filed against life and health insurers in the jurisdictions in which MLOA does business involving insurers' sales practices, alleged agent misconduct, alleged failure to properly supervise agents, contract administration and other matters. Some of the lawsuits have resulted in the award of substantial judgments against other insurers, including material amounts of punitive damages, or in substantial settlements. In some states, juries have substantial discretion in awarding punitive damages. MLOA, like other life and health insurers, from time to time is involved in such litigations. Some of these actions and proceedings filed against MLOA have been brought on behalf of various alleged classes of claimants and certain of these claimants seek damages of unspecified amounts. While the ultimate outcome of such matters cannot be predicted with certainty, in the opinion of management no such matter is likely to have a material adverse effect on MLOA's financial position or results of operations. However, it should be noted that the frequency of large damage awards, including large punitive damage awards that bear little or no relation to actual economic damages incurred by plaintiffs in some jurisdictions, continues to create the potential for an unpredictable judgment in any given matter.

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BALANCE SHEETS (USD $) In Millions	Jun. 30, 2011	Dec. 31, 2010
ASSETS
Fixed maturities available for sale, at fair value	$ 1,974	$ 1,900
Mortgage loans on real estate	132	141
Policy loans	135	132
Other invested assets	78	78
Total investments	2,319	2,251
Cash And Cash Equivalents At Carrying Value	24	92
Amounts due from reinsurers	136	139
Deferred policy acquisition costs	214	189
Value of business acquired	100	107
Other assets	28	29
Separate Accounts asset	1,805	1,840
Total Assets	4,626	4,647
LIABILITIES
Policyholders account balances	1,625	1,664
Future policy benefits and other policyholders liabilities	380	378
Other liabilities	45	42
Income taxes payable	116	118
Separate Accounts liabilities	1,805	1,840
Total liabilities	3,971	4,042
Commitments and contingent liabilities (Note 10)	0	0
SHAREHOLDERS EQUITY
Common Stock, $1.00 par value; 5.0 million shares authorized, 2.5 million issued and outstanding	2	2
Capital in excess of par value	514	514
Retained earnings	92	44
Accumulated other comprehensive income (loss)	47	45
Total equity	655	605
Total Liabilities and Equity	$ 4,626	$ 4,647