MEMBERS Life Insurance Company
Britney Schnathorst | |
Associate General Counsel | |
Office of General Counsel | |
Phone: | 608.665.4184 |
E-mail: | Britney.schnathorst@cunamutual.com |
May 9, 2023
VIA EDGAR TRANSMISSION
Ms. Elisabeth Bentzinger, Esq.
Senior Counsel, Disclosure Review Office No. 3
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: | MEMBERS Life Insurance Company TruStage™ ZoneChoice Annuity |
Initial to Registration Statement on Form S-1
Dear Commissioners:
On behalf of MEMBERS Life Insurance Company (the “Company”), we are providing responses to comments received from the staff (“Staff”) of the Securities and Exchange Commission (the “Commission” or “SEC”). We are transmitting for filing an initial Registration Statement on Form S-1 (the “Registration Statement”) for certain single premium deferred annuity contracts with index-linked interest options (the “Contracts”). The purpose of this filing is to include enhancements to the current Contract under the Securities Act of 1933 (the “1933 Act”).
The Registration Statement will incorporate changes made in response to comments raised by the Staff. For the Staff’s convenience, each comment is set forth in full below, followed by the response. Acceleration requests from the Company and the principal underwriter also accompany the filing.
1. | Please provide a white paper or fact sheet for the Dimensional US Small Cap Value Systematic Index. |
Response Attached.
2. | Please confirm that the index information for the Dimensional US Small Cap Value Systematic Index will be published publicly. |
Response: Confirmed.
3. | Please confirm that the Dimensional US Small Cap Value Systematic Index is a rules-based index. |
Response: Confirmed.
4. | Please supplementally provide more detail about the relationship between the index provider and the Registrant, and confirm that the Dimensional US Small Cap Value Systematic Index is not proprietary to the Registrant. |
Response: | The Dimensional US Small Cap Value Systematic Index is proprietary to Dimensional Fund Advisers, who operate the index. Dimensional Fund Advisers is not an affiliate of the Registrant. |
Ms. Bentzinger
May 9, 2023
Page 2
If you have any questions regarding this letter or the Registration Statement, please contact the undersigned at 608-665-4184. We greatly appreciate the Staff’s efforts in assisting the Company with this filing.
Sincerely,
/s/Britney Schnathorst
Britney Schnathorst
cc: | Ms. Elisabeth Bentzinger |
Mr. Thomas Bisset |
Attachment