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MUTUAL OF AMERICA |
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LIFE INSURANCE COMPANY |
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| NEW YORK NY 10022-6839 |
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| 212 224 1562 |
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| 212 224 2518 FAX |
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| THOMAS L. MARTIN |
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| EXECUTIVE VICE PRESIDENT AND |
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| DEPUTY GENERAL COUNSEL |
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| CORPORATE LAW |
Via Edgar Correspondence
April 28, 2010
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1520
RE: Mutual of America Life Insurance Company
Securities Account No. 2 (457) (the “Registrant”)
Form N-4 Registration Statement
Post-Effective Amendment No. 36 under the Securities Act of 1933, as
amended (“1933 Act”) and Amendment No. 38 under the Investment
Company Act of 1940, as amended (“1940 Act”)
File Nos. 033-05609 and 811-03996 (“filing”)
Ladies and Gentlemen:
Mutual of America and Registrant filed Post-Effective Amendment No. 36 under the 1933 Act and Amendment No. 38 under the 1940 Act to the above-referenced Registration Statement on form N-4 on February 24, 2010.
In connection with this filing, the Registrant acknowledges that:
1. The Registrant is responsible for the adequacy and accuracy of the disclosure in the filings;
2. The Securities and Exchange Commission (“Commission”) staff (“Staff”) comments or changes to disclosure in response to Staff comments in the filings reviewed by the Staff do not foreclose the Commission from taking any action with respect to the filings; and
3. The Registrant may not assert Staff comments as a defense in any proceedings initiated by the Commission or any person under the federal securities laws of the United States.
Sincerely, |
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/s/ Thomas L. Martin |
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Thomas L. Martin |
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