| 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 1562 |
| 212 224 2518 FAX |
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| THOMAS L. MARTIN |
| EXECUTIVE VICE PRESIDENT AND |
| DEPUTY GENERAL COUNSEL |
| CORPORATE LAW |
April 30, 2010
Via EDGAR correspondence
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Mutual of America Investment Corporation
Post-Effective Amendment to Registration Statement on Form N-1A
(File no. 033-06486 and 811-05084)
Filed pursuant to Rule 485(b) of the Securities Act of 1933
Commissioners:
As in-house counsel for Mutual of America Life Insurance Company, I participated in the preparation of the above referenced Post-Effective Amendment filed on the date hereof. Such Post-Effective Amendment does not contain disclosures that would render it ineligible to become effective under Rule 485(B) of the Securities Act of 1933.
Sincerely,
/s/ Thomas L. Martin |
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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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MUTUAL OF AMERICA |
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LIFE INSURANCE COMPANY |
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| NEW YORK NY 10022-6839 |
| 212 224 1562 |
| 212 224 2518 FAX |
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| THOMAS L. MARTIN |
| EXECUTIVE VICE PRESIDENT AND |
| DEPUTY GENERAL COUNSEL |
| CORPORATE LAW |
Via Edgar Correspondence
April 30, 2010
Mr. Sonny Oh
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549-1520
RE: | Post-Effective Amendment No. 34 under the Securities Act of 1933 |
| and Post Effective Amendment No. 35 under the Investment Company Act of 1940 |
| to the Registration Statement on Form N-1A of Mutual of America Investment Corporation |
| SEC File Nos. 033-06486 and 811-05084 (Prospectus and S.A.I.) |
Dear Mr. Oh:
Mutual of America and Registrant filed Post-Effective Amendment No. 34 under the 1933 Act and Amendment No. 35 under the 1940 Act to the above-referenced Registration Statement on form N-1A on February 18, 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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