Mutual Of America Separate Account No 2 CORRESP Correspondence with SEC

MUTUAL OF AMERICA

LIFE INSURANCE COMPANY

320 PARK AVENUE

NEW YORK NY  10022-6839

212 224 1562

212 224 2518FAX

THOMAS L. MARTIN

SENIOR VICE PRESIDENT AND

ASSOCIATE GENERAL COUNSEL

CORPORATE LAW

Via EDGAR Correspondence

April 22, 2008

Sonny Oh, Esq.

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC  20549

RE: Comments on Post Effective Amendment No. 33 to Registration Statement on Form N-4 of Mutual of America Separate Account No. 2 (Thrift Plan Contracts) (File Nos. 33-11023 and 811-4679)

Dear Mr. Oh:

This letter is intended to respond to your request that the Registrant address certain of your comments prior to filing its 485 (b) Annual Update to be effective May 1, 2008.

The comments addressed herein are those designated by you for such early response in your April 14, 2008 telephone call with Ms. Edson and the undersigned.  The remainder of the comments discussed in that telephone call are being incorporated into the relevant documents included in the 485(b) filing and/or are to be addressed in a letter accompanying the filing.  If this is not acceptable, please let me know at once.

You identified three questions to be covered by this initial letter:

(1)

Comment: Confirm whether there are any third party guarantees or support agreements for payment of benefits under the annuity contracts.  

Response: This will confirm that the disclosure contained in the 2007 prospectus under the caption “About Mutual of America and the Separate Account,” which shall remain unchanged in the current filing, as follows:

“We have no support agreements with, or guarantees from, third parties for the payment of benefits under our Contracts.  We are responsible for the payment of all such benefits.”

(2)

Comment: You requested confirmation that the EDGAR class identifier matches the designation, “Thrift Plan Contracts,” which appears on the cover of the prospectus.  

Response: This will confirm that the EDGAR Class identifier is for “Thrift Plan Contracts”.  It has been noted that the first page of text in the prospectus is captioned, “Variable Accumulation Annuity Contracts for Thrift Plans.”  This caption will be amended to read, “Thrift Plan Contracts – Variable Accumulation Annuity Contracts for Thrift Plans.”

(3)

Comment: You requested an explanation for the deletion of the cancellation provisions under the subheading “Annuity Commencement Date and Amount of Monthly Payment” on page 12 of the draft prospectus and on page 21 of the draft prospectus under the subheading, “Purchase of a Contract; Participation.”  

Response: Both of these provisions relate to the cancellation of 403(b) certificates, issued under group contracts, which are not required by state law to provide for cancellation during the “free look” period.  The disclosures proposed for deletion, on page 12 and on page 21, state that under newer versions of the Contracts the right of cancellation is not included.  It appears that, despite the absence of a legal requirement for same, there may have been a contractual ten-day cancellation right under old contracts.  There are currently no 403(b) contracts outstanding that contain such a provision.  The purpose of the proposed deletion is to prevent confusion by eliminating this disclosure that is no longer applicable.

I hope that the foregoing satisfactorily responds to your requests for our initial response prior to the effective date of the Annual Update.  The Annual Update documents containing our responses to your comments, and an accompanying explanatory letter will be filed subsequent to this letter, along with the customary Tandy representations.  If you have any further comments or if you wish to further discuss the above, please feel free to call me at 212-224-1562 or Elizabeth Edson at 212-224-1564.

Very truly yours,

/s/ Thomas L. Martin