January 21, 2010
Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, NE
Washington, DC 20549-4720
Re: | American Equity Investment Life Holding Company |
Dear Mr. Rosenberg:
We received your comment later dated January 12, 2010 requesting a response within 10 business days. We expect to submit a response to comments 1 — 4 early next week within that time frame. Upon consultation with other members of management and our outside legal counsel, we have determined that we will need some additional time beyond 10 business days to appropriately respond to comment 5 which requests a draft disclosure of the Compensation Discussion & Analysis for our 2010 Definitive Proxy Statement. We expect to submit our response to comment 5 early in the week of February 8, 2010 which would be within approximately 20 business days.
Sincerely,
/s/ John M. Matovina
John M. Matovina
Chief Financial Officer and Treasurer
