| MUTUAL OF AMERICA |
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MUTUAL OF AMERICA |
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LIFE INSURANCE COMPANY |
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| 320 PARK AVENUE |
| NEW YORK NY 10022-6839 |
| 212 224 1840 |
| 212 224 2518 FAX |
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| AMY LATKIN |
| VICE PRESIDENT AND |
| ASSISTANT GENERAL COUNSEL |
| CORPORATE LAW |
February 24, 2010
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: | Mutual of America Separate Account No. 2 (TVIF Contracts) (the “Registrant”) |
Ladies and Gentlemen:
Contemporaneously herewith the above named Registrant is filing a post-effective amendment under Rule 485(a) of the Securities Act of 1933. This is to advise that the post-effective amendment being filed contemporaneously herewith includes an increase in the Separate Account Annual Expenses found in the Tables of Annual Expenses section, a new pricing structure, with the introduction of new criteria for reduced fees and an additional level of reduced fees beyond the single tier presently offered. The new fee structure is intended to take effect on or after August 1, 2010.
Also, Inherited IRAs will be added to the IRA Contracts, subject to approval from the state insurance department. Individuals, whether a surviving Spouse or a beneficiary, may purchase an Inherited IRA when offered in the individual’s state, using death benefit proceeds payable under an IRA or another qualified retirement plan. The prospectus also explains Contributions to an Inherited IRA, Annuitants and Beneficiaries, and the treatment of an Inherited IRA for federal income tax purposes.
Other changes were made throughout the prospectus that may be material. For your convenience, please contact us if you would like to see the marked prospectus in Word format and we will send that to you directly.
Sincerely, |
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/s/ Amy Latkin |
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Amy Latkin |
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Vice President and |
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Assistant General Counsel |
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