424(b)(3)
                                                                      333-155348






Individual Flexible Payment Variable
Annuity Contract

Issued by MONY Life Insurance Company of America with variable investment
options under MONY America's MONY America Variable Account A.


PROSPECTUS DATED MAY 1, 2011


Please read and keep this prospectus for future reference. It contains
important information that you should know before purchasing, or taking any
other action under your Contract. Also, you should read the prospectuses for
each Trust, which contain important information about their portfolios.

--------------------------------------------------------------------------------


MONY Life Insurance Company of America (the "Company") issues the flexible
payment variable annuity contract described in this prospectus. This prospectus
is a disclosure document and describes all of the Contract's material features,
benefits, rights and obligations, as well as other information. The description
of the Contract's material provisions in this prospectus is current as of the
date of this prospectus. If certain material provisions under the Contract are
changed after the date of this prospectus in accordance with the Contract,
those changes will be described in a supplement to this prospectus. You should
carefully read this prospectus in conjunction with any applicable supplements.


This Contract is no longer being sold. This prospectus is used with current
contract owners only. We will continue to accept Purchase Payments under
existing Contracts. You should note that your Contract features and charges,
and your investment options, may vary depending on your state and/or the date
on which you purchased your Contract. For more information about the particular
features, charges and options applicable to you, please contact your financial
professional and/or refer to your Contract.

You can tell us what to do with your Purchase Payments. You can also tell us
what to do with the fund value your Contract may create for you resulting from
those Purchase Payments.


You may allocate some or all of your Purchase Payments into the subaccounts.
Each subaccount is a subaccount of separate account MONY America Variable
Account A. Both the value of your Contract before the date annuity payments
begin and the amount of income afterward will depend on the investment
performance of the portfolios you select. You bear the investment risk of
investing in the portfolios. The subaccounts invest in shares of the following
portfolios of AIM Variable Insurance Funds, AXA Premier VIP Trust, EQ Advisors
Trust, Franklin Templeton Variable Insurance Products Trust, Janus Aspen
Series, MFS(R) Variable Insurance Trust(SM), Oppenheimer Variable Account Funds,
PIMCO Variable Insurance Trust and ProFunds VP (the "Funds").







--------------------------------------------------------------------------------
 SUBACCOUNTS
--------------------------------------------------------------------------------
                                      
o All Asset Allocation                   o EQ/Morgan Stanley Mid Cap Growth
o AXA Aggressive Allocation(1)           o EQ/PIMCO Ultra Short Bond
o AXA Conservative Allocation(1)         o EQ/Small Company Index
o AXA Conservative-Plus Allocation(1)    o EQ/UBS Growth and Income
o AXA Moderate Allocation(1)             o Franklin Income Securities
o AXA Moderate-Plus Allocation(1)        o Franklin Rising Dividends Securities
o EQ/AllianceBernstein Small Cap         o Invesco Van Kampen V.I. Global Value
   Growth                                   Equity
o EQ/BlackRock Basic Value Equity        o Invesco V.I. Dividend Growth(4)
o EQ/Boston Advisors Equity Income       o Invesco V.I. Global Health Care
o EQ/Calvert Socially Responsible        o Invesco V.I. Technology Fund
o EQ/Capital Guardian Research           o Janus Aspen Forty
o EQ/Core Bond Index                     o Janus Aspen Overseas
o EQ/GAMCO Mergers and Acquisitions      o MFS(R) Utilities Series
o EQ/GAMCO Small Company Value           o Multimanager Multi-Sector Bond
o EQ/Global Multi-Sector Equity          o Multimanager Small Cap Growth
o EQ/Intermediate Government Bond        o Oppenheimer Global Securities
   Index                                    Fund/VA
o EQ/Large Cap Value Index(2)            o PIMCO VIT Global Bond (Unhedged)
o EQ/Large Cap Value PLUS                o ProFund VP Bear
o EQ/Lord Abbett Growth and Income (3)   o ProFund VP Rising Rates Opportunity
o EQ/Mid Cap Index                       o ProFund VP UltraBull
o EQ/Mid Cap Value PLUS
o EQ/Money Market
o EQ/Montag & Caldwell Growth
--------------------------------------------------------------------------------



NOT ALL OF THESE PORTFOLIOS MAY BE AVAILABLE IN ALL STATES OR ALL MARKETS.


(1)  The "AXA Allocation" portfolios.

(2)  This subaccount will become available on or about May 20, 2011. Please see
     "the Funds" later in this prospectus for more information about this
     subaccount.

(3)  Please see "The Funds" later in this prospectus regarding the proposed
     merger of this variable investment option on or about May 20, 2011.

(4)  This variable investment option has been added to the contract as a result
     of a merger. Please see "the Funds" later in this prospectus for more
     information about this subaccount.


You may also allocate some or all of your Purchase Payments and fund values
into our Guaranteed Interest Account with Market Value Adjustment, which is
discussed later in this prospectus.


Among the many terms of the Guaranteed Interest Account with Market Value
Adjustment are:

o    Guaranteed interest to be credited for specific periods (referred to as
     "Accumulation Periods").

o    Three (3), five (5), seven (7), and ten (10) year Accumulation Periods are
     available. The one (1) year Accumulation Period is limited to the following
     states: Maryland, the Commonwealth of Massachusetts, New Jersey, Oklahoma,
     Oregon, the Commonwealth of Pennsylvania, South Carolina, Texas and
     Washington.


THE SEC HAS NOT APPROVED OR DISAPPROVED THESE SECURITIES OR DETERMINED IF THIS
PROSPECTUS IS ACCURATE OR COMPLETE. ANY REPRESENTATION TO THE CONTRARY IS A
CRIMINAL OFFENSE. THE CONTRACTS ARE NOT INSURED BY THE FDIC OR ANY OTHER
AGENCY. THEY ARE NOT DEPOSITS OR OTHER OBLIGATIONS OF ANY BANK AND ARE NOT BANK
GUARANTEED. THEY ARE SUBJECT TO INVESTMENT RISKS AND POSSIBLE LOSS OF
PRINCIPAL.

                                                                   e13454/MLA-VA



o    Interest will be credited for the entire Accumulation Period on a daily
     basis. Different rates apply to each Accumulation Period and are determined
     by the Company from time to time at its sole discretion.

o    A market value adjustment may be charged if part or all of the Guaranteed
     Interest Account with Market Value Adjustment is surrendered or transferred
     before the end of the Accumulation Period.

o    Contract owners should carefully consider the information contained in this
     prospectus before allocating Purchase Payments or Fund Values to the
     Guaranteed Interest Account with Market Value Adjustment offered herein.

--------------------------------------------------------------------------------
These are only some of the terms of the Guaranteed Interest Account with Market
Value Adjustment. Please read this prospectus carefully for more complete
details of the contract.
--------------------------------------------------------------------------------


A Statement of Additional Information dated May 1, 2011 containing additional
information about the contract is incorporated herein by reference. It has been
filed with the Securities and Exchange Commission and is available from the
Company without charge upon written request. You may request one by writing to
our processing office located at MONY Life Insurance Company of America,
Policyholder Services, 100 Madison Street, Syracuse, New York 13202, by
telephoning 1-800-487-6669 or by accessing the SEC's website at www.sec.gov.
The Table of Contents of the Statement of Additional Information can be found
on the last page of this prospectus.




                                         Contents of this Prospectus


--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
1. SUMMARY OF THE CONTRACT                                                    4
--------------------------------------------------------------------------------
Definitions                                                                   4
Purpose of the Contract                                                       4
Purchase Payments and fund value                                              4
Minimum Purchase Payments                                                     4
MONY America Variable Account A                                               4
Guaranteed Interest Account with Market Value Adjustment                      4
The Accumulation Periods                                                      5
Crediting of interest                                                         5
The Market Value Adjustment                                                   5
Benefit option packages                                                       6
Transfer of fund value                                                        8
Loans                                                                         8
Surrenders                                                                    8
Charges and deductions                                                        8
Right to return contract provision                                            8
Death benefit                                                                 8
Fee tables                                                                    9
Example                                                                      10
Other contracts                                                              11
Condensed financial information                                              11


--------------------------------------------------------------------------------
2. WHO IS MONY LIFE INSURANCE COMPANY OF AMERICA?                            12
--------------------------------------------------------------------------------
MONY Life Insurance Company of America                                       12
How to reach us                                                              12
MONY America Variable Account A                                              12


--------------------------------------------------------------------------------
3. THE FUNDS                                                                 14
--------------------------------------------------------------------------------
Purchase of portfolio shares by MONY America Variable Account A              19


--------------------------------------------------------------------------------
4. DETAILED INFORMATION ABOUT THE CONTRACT                                   20
--------------------------------------------------------------------------------
Payment and allocation of Purchase Payments                                  20
Telephone/fax/web transactions                                               23
Disruptive transfer activity                                                 24
Termination of the Contract                                                  25


                                                  CONTENTS OF THIS PROSPECTUS  2



--------------------------------------------------------------------------------
5. DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT
   WITH MARKET VALUE ADJUSTMENT                                              26
--------------------------------------------------------------------------------
General                                                                      26
Guaranteed Interest Account with Market Value Adjustment                     26
Allocations to the Guaranteed Interest Account with Market
   Value Adjustment                                                          26
Specified interest rates and the accumulation periods                        26
Surrenders, transfers or loans                                               28
The Market Value Adjustment                                                  28
Investments                                                                  29


--------------------------------------------------------------------------------
6. SURRENDERS                                                                30
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
7. LOANS                                                                     31
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
8. DEATH BENEFIT                                                             32
--------------------------------------------------------------------------------
Death benefit provided by the Contract                                       32
Earnings increase death benefit                                              33
Election and effective date of election                                      34
Payment of death benefit proceeds                                            34


--------------------------------------------------------------------------------
9. CHARGES AND DEDUCTIONS                                                    35
--------------------------------------------------------------------------------
Deductions from Purchase Payments                                            36
Charges against Fund Value                                                   36
Deductions from Fund Value                                                   36


--------------------------------------------------------------------------------
10. ANNUITY PROVISIONS                                                       39
--------------------------------------------------------------------------------
Annuity payments                                                             39
Guaranteed minimum annuity payments                                          39
Election and change of settlement option                                     39
Settlement options                                                           40
Frequency of annuity payments                                                40
Additional provisions                                                        40


--------------------------------------------------------------------------------
11. OTHER PROVISIONS                                                         42
--------------------------------------------------------------------------------
Ownership                                                                    42
Provision required by Section 72(s) of the Code                              42
Provision required by Section 401(a)(9) of the Code                          42
Secondary annuitant                                                          42
Assignment                                                                   43
Change of beneficiary                                                        43
Substitution of securities                                                   43
Changes to Contracts                                                         43
Change in operation of MONY America Variable Account A                       43


--------------------------------------------------------------------------------
12. VOTING RIGHTS                                                            44
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
13. DISTRIBUTION OF THE CONTRACTS                                            45
--------------------------------------------------------------------------------

--------------------------------------------------------------------------------
14. FEDERAL TAX STATUS                                                       47
--------------------------------------------------------------------------------
Introduction                                                                 47


Taxation of annuities in general                                             47


Retirement plans                                                             47
Tax treatment of the Company                                                 48


--------------------------------------------------------------------------------
15. ADDITIONAL INFORMATION AND INCORPORATION OF CERTAIN INFORMATION BY
    REFERENCE                                                                 49
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
16. LEGAL PROCEEDINGS                                                        50
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
17. FINANCIAL STATEMENTS                                                     51
--------------------------------------------------------------------------------


About the general account                                                    51



--------------------------------------------------------------------------------
APPENDICES
--------------------------------------------------------------------------------
     I --   Benefit option packages, table of fees,                          I-1
              examples and charges and deductions for
              contracts issued in the State of Washington
    II --   Condensed financial information                                 II-1

--------------------------------------------------------------------------------
STATEMENT OF ADDITIONAL INFORMATION
    TABLE OF CONTENTS
--------------------------------------------------------------------------------





3  CONTENTS OF THIS PROSPECTUS



1. SUMMARY OF THE CONTRACT


--------------------------------------------------------------------------------


This summary provides you with a brief overview of the more important aspects
of your Contract, including the Guaranteed Interest Account with Market Value
Adjustment. It is not intended to be complete. More detailed information is
contained in this prospectus on the pages following this summary and in your
Contract. This summary and the entire prospectus will describe the part of the
Contract involving MONY America Variable Account A. The prospectus also briefly
will describe the Guaranteed Interest Account with Market Value Adjustment and
the portfolios offered by AIM Variable Insurance Funds, AXA Premier VIP Trust,
EQ Advisors Trust, Franklin Templeton Variable Insurance Products Trust, Janus
Aspen Series, MFS(R) Variable Insurance Trust(SM), Oppenheimer Variable Account
Funds, PIMCO Variable Insurance Trust and ProFunds VP. See applicable fund
prospectuses for more detailed information about the portfolios offered by the
Funds.



DEFINITIONS
--------------------------------------------------------------------------------
Specialized terms will be defined on the page where they first appear enclosed
in a box.
--------------------------------------------------------------------------------

PURPOSE OF THE CONTRACT


The Contract is an Individual Flexible Payment Variable Annuity Contract (the
"Contract" or "Contracts"). The Contract is no longer being sold. We will
continue to accept Purchase Payments under existing Contracts.

The Contract is designed to allow an owner to make Purchase Payments to the
Company under the Contract. Those Purchase Payments are allocated at the
owner's choice among the subaccounts of MONY America Variable Account A and the
Guaranteed Interest Account with Market Value Adjustment. Those Purchase
Payments can accumulate for a period of time and create fund value for the
owner. The owner can choose the length of time that such Purchase Payments may
accumulate. The owner may choose at some point in the future to receive annuity
benefits based upon that accumulated fund value.

An owner uses the Contract's design to accumulate fund value for various
purposes including retirement or to supplement other retirement programs. Some
of these retirement programs (the "Qualified Plans") may qualify for federal
income tax advantages available under certain sections of the Internal Revenue
Code (the "Code"). Sections 401,403 (other than Section 403(b)), 408, 408A and
457, for example.

--------------------------------------------------------------------------------
QUALIFIED PLANS -- Retirement plans that may receive favorable tax treatment
under certain Sections of the Code.
QUALIFIED CONTRACTS -- Contracts issued under Qualified Plans.
NON-QUALIFIED CONTRACTS -- Contracts not issued under Qualified Plans.
--------------------------------------------------------------------------------

The Contract is also designed to allow the owner to request payments of part or
all of the accumulated fund values before the owner begins to receive annuity
benefits. This payment may result in the imposition of a surrender charge and a
market value adjustment. The market value adjustment will not apply to
Contracts issued in certain states. These payments also may be subject to a
contract charge and/or income or other taxes.

PURCHASE PAYMENTS AND FUND VALUE

You may allocate your Purchase Payments to one or more of the subaccounts of
MONY America Variable Account A that are available under the Contract and/or to
the Guaranteed Interest Account with Market Value Adjustment. The Purchase
Payments you allocate among the various subaccounts of MONY America Variable
Account A may increase or decrease in value on any day depending on the
investment experience of the subaccounts you select. There is no guarantee that
the value of the Purchase Payments you allocate to any of the subaccounts of
MONY America Variable Account A will increase or that the Purchase Payments you
make will not lose value.


MINIMUM PURCHASE PAYMENTS

The minimum Purchase Payment for individuals varies depending upon the
purchaser of the Contract, the method of paying the Purchase Payments and the
benefit option package selected. (See "Payment and allocation of Purchase
Payments.")

Additional Purchase Payments may be made at any time.


MONY AMERICA VARIABLE ACCOUNT A

MONY America Variable Account A is a separate investment account of MONY Life
Insurance Company of America (the "Company"). MONY America Variable Account A's
assets are owned by the Company, but are not chargeable with liabilities
arising from any other business the Company conducts.

The subaccounts of MONY America Variable Account A invest in shares of the
Funds at their net asset value. (See "The Funds"). Owners bear the entire
investment risk for all amounts allocated to MONY America Variable Account A
subaccounts.

--------------------------------------------------------------------------------
FUND -- Any open-end management investment company or unit investment trust in
which a subaccount invests.
OWNER -- The person so designated in the application to whom all rights,
benefits, options and privileges apply while the Annuitant is living. If a
Contract has been absolutely assigned, the assignee becomes the Owner.
PURCHASE PAYMENT -- An amount paid to the Company by the Owner or on the
Owner's behalf as consideration for the benefits provided by the Contract.
NET PURCHASE PAYMENT -- Purchase Payment less any applicable tax charge.
--------------------------------------------------------------------------------

GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT

The Guaranteed Interest Account with Market Value Adjustment is part of the
Company's general account ("General Account"). It consists of all the Company's
assets other than assets allocated to separate investment accounts of the
Company. Net Purchase Payments allocated to the Guaranteed Interest Account
with Market Value Adjustment will be credited with interest at rates guaranteed
by the Company for specified periods. (See "Description of the Guaranteed
Interest Account with Market Value Adjustment".)

The Guaranteed Interest Account with Market Value Adjustment is designed to
provide you with an opportunity to receive a guaranteed


                                                      SUMMARY OF THE CONTRACT  4



fixed rate of interest. You can choose the period of time over which the
guaranteed fixed rate of interest will be paid. That period of time is known as
the Accumulation Period.

The Guaranteed Interest Account with Market Value Adjustment is also designed
to provide you with the opportunity to transfer part or all of the Guaranteed
Interest Account with Market Value Adjustment to the Subaccounts available to
you under the Contract. It is also designed to provide you with the opportunity
to surrender part or all of the Guaranteed Interest Account with Market Value
Adjustment before the end of the Accumulation Period. If you ask us to transfer
or surrender part or all of the Guaranteed Interest Account, we may apply a
market value adjustment ("MVA"). This adjustment may be positive, negative, or
zero.

You may allocate all or part of your Purchase Payments to the Guaranteed
Interest Account with Market Value Adjustment.

THE ACCUMULATION PERIODS

There are 4 different Accumulation Periods currently available: a 3-year
Accumulation Period, a 5-year Accumulation Period, a 7-year Accumulation
Period, and a 10-year Accumulation Period. Certain states limit contracts to a
1-year Accumulation Period. You may allocate initial or additional Purchase
Payments made under the Contract to one or more Accumulation Periods. You may
also ask us to transfer Fund Values from the Subaccounts available under the
Contract to one or more of the Accumulation Periods subject to any applicable
MVA. There is no minimum amount required for allocation or transfer to an
Accumulation Period. (See "Allocations to the Guaranteed Interest Account with
Market Value Adjustment.")

Each Accumulation Period starts on the Business Day that falls on, or next
follows, the date on which allocations are made and Purchase Payments are
received or Fund Values are transferred. Each Accumulation Period ends on the
Monthly Contract Anniversary immediately prior to the 3, 5, 7 or 10 year
anniversary of the start of the Accumulation Period (the "Maturity Date"). This
means that the Accumulation Period for a 3, 5, 7 or 10 year Accumulation Period
may be up to 31 days shorter than 3, 5, 7 or 10 years, respectively. (See
"Specified interest rates and the accumulation periods.")

CREDITING OF INTEREST

The Company will credit amounts allocated to an Accumulation Period with
interest at an annual rate not less than 3.50%. This interest rate is referred
to as the Specified Interest Rate. It will be credited for the duration of the
Accumulation Period. Specified Interest Rates for each Accumulation Period are
declared periodically at the sole discretion of the Company. (See "Specified
interest rates and the accumulation periods.")

At least 15 days and at most 45 days prior to the Maturity Date of an
Accumulation Period, Owners having Fund Values allocated to such Accumulation
Periods will be notified of the impending Maturity Date. Owners will then have
the option of directing the surrender or transfer (including transfers for the
purpose of obtaining a Loan) of the Fund Value within 30 days before the end of
the Accumulation Period without application of any MVA.

The Specified Interest Rate will be credited to amounts allocated to an
Accumulation Period, so long as such allocations are neither surrendered nor
transferred prior to the Maturity Date for the Allocation Period. The Specified
Interest Rate is credited daily, providing an annual effective yield. (See
"Specified interest rates and the accumulation periods.")

THE MARKET VALUE ADJUSTMENT

Amounts that are surrendered or transferred (including transfers for the
purpose of obtaining a Loan) from an Accumulation Period more than 30 days
before the Maturity Date will be subject to an MVA. An MVA will not apply upon
payment of a death benefit upon the death of the annuitant. The MVA is
determined through the use of a factor, which is known as the MVA Factor. This
factor is discussed in detail in the section entitled "The Market Value
Adjustment." The MVA could cause an increase or decrease or no change at all in
the amount of the distribution from an Accumulation Period.

A MARKET VALUE ADJUSTMENT WILL NOT BE IMPOSED ON CONTRACTS ISSUED IN MARYLAND,
THE COMMONWEALTH OF MASSACHUSETTS, NEW JERSEY, OKLAHOMA, OREGON, THE
COMMONWEALTH OF PENNSYLVANIA, SOUTH CAROLINA, TEXAS AND WASHINGTON; HOWEVER,
RESTRICTIONS ON TRANSFERS APPLY IN THESE STATES. The adjustment can be either a
positive or negative adjustment. No adjustment is made for the amount withdrawn
or transferred within 30 days before the end of the accumulation period.

--------------------------------------------------------------------------------
FUND VALUE -- The aggregate dollar value as of any Business Day of all amounts
accumulated under each of the subaccounts, the Guaranteed Interest Account, and
the loan account of the Contract. If the term Fund Value is preceded or
followed by the terms subaccount(s), the Guaranteed Interest Account, and the
loan account, or any one or more of those terms, Fund Value means only the Fund
Value of the subaccount, the Guaranteed Interest Account or the loan account,
as the context requires.
BUSINESS DAY -- Our "business day" is generally any day the New York Stock
Exchange is open for regular trading and generally ends at 4:00 p.m. Eastern
Time (or as of an earlier close of regular trading). A business day does not
include a day on which we are not open due to emergency conditions determined
by the Securities and Exchange Commission. We may also close early due to such
emergency conditions.
MONTHLY CONTRACT ANNIVERSARY -- The date of each month corresponding to the
Effective Date of the Contract. For example, for a Contract with a June 15
Effective Date, the Monthly Contract Anniversary is the 15th of each month. If
a Contract's Effective Date falls on the 29th, 30th or 31st day of a month, the
Monthly Contract Anniversary will be the earlier of that day or the last day of
the particular month in question.
--------------------------------------------------------------------------------

5  SUMMARY OF THE CONTRACT



BENEFIT OPTION PACKAGES


There are two benefit option packages under Contracts issued in the state of
Washington--see Appendix I for a table summarizing the benefit option packages.
Each benefit option package is distinct. You select a benefit option package at
the time of application. Once a selection is made, you may not transfer from
one benefit option package to another.





------------------------------------------------------------------------------------------------------------------------------------
                             OPTION 1                         OPTION 2                          OPTION 3(3)
------------------------------------------------------------------------------------------------------------------------------------
                                                                                       
MORTALITY AND EXPENSE RISK   Current annual rate--1.20%       Current annual rate--1.70%        Current annual rate--2.35%
CHARGE                       Maximum annual rate--1.40%       Maximum annual rate--1.95%        Maximum annual rate--2.80%
------------------------------------------------------------------------------------------------------------------------------------
DEATH BENEFIT ON DEATH OF    THE GREATER OF:                  THE GREATEST OF:                  THE GREATEST OF:
ANNUITANT                    (1)  The Fund Value less any     (1)  The Fund Value less any      (1)  The Fund Value less any
                                  outstanding debt on the          outstanding debt on the           outstanding debt on the
                                  date due proof of the            date due proof of the             date due proof of the
                                  Annuitant's death is             Annuitant's death is              Annuitant's death is
                                  received by the                  received by the                   received by the
                                  Company.                         Company.                          Company.

                                           or                             or                                   or

                                                              (2)  The Purchase Payments        (2)  The Purchase Payments
                             (2)  The Purchase Payments            paid, reduced                     paid, reduced
                                  paid, reduced                    proportionately by each           proportionately by each
                                  proportionately by each          partial surrender                 partial surrender
                                  partial surrender                (reflecting any market            (reflecting any market
                                  (reflecting any market           value adjustment and              value adjustment and
                                  value adjustment and             any surrender charge)             any surrender charge)
                                  any surrender charge)            and less any                      and less any out-
                                  and less any                     outstanding debt.(1)              standing debt.(1)
                                  outstanding debt.(1)
                                                                          or                                  or

                                                              (3)  Step Up Value (See           (3)  Step Up Value (See
                                                                   "Death benefit").                 "Death Benefit").

                                                                                                              or

                                                                                                (4)  Roll Up Value (See
                                                                                                     "Death benefit").
------------------------------------------------------------------------------------------------------------------------------------
EARNINGS INCREASE AMOUNT     Not Available                    The amount of the Earnings        The amount of the Earnings
ADDED TO DEATH BENEFIT                                        Increase depends upon the         Increase depends upon the
                                                              age of the Annuitant on the       age of the Annuitant on the
                                                              Contract's Effective Date.        Contract's Effective Date.

                                                              If the Annuitant was age 69       If the Annuitant was age 69
                                                              or younger on the Contract's      or younger on the Contract's
                                                              Effective Date, the Earnings      Effective Date, the Earnings
                                                              Increase Amount is equal to       Increase Amount is equal to
                                                              40% of the lesser of:             40% of the lesser of:

                                                              (1)  Net Purchase Payments;       (1)  Net Purchase Payments;

                                                                             or                             or

                                                              (2)  Fund Value minus             (2)  Fund Value minus
                                                                   Purchase Payments.(2)             Purchase Payments.(2)

                                                                   If the Annuitant was              If the Annuitant was
                                                                   age 70 or older on the            age 70 or older on the
                                                                   Contract's Effective              Contract's Effective
                                                                   Date, the Earnings                Date, the Earnings
                                                                   Increase Amount is                Increase Amount is
                                                                   equal to 25% of the               equal to 25% of the
                                                                   lesser of:                        lesser of:

                                                              (1)  Net Purchase Payments;       (1)  Net Purchase Payments;

                                                                             or                              or

                                                              (2)  Fund Value minus             (2)  Fund Value minus
                                                                   Purchase Payments.(2)             Purchase Payments.(2)
------------------------------------------------------------------------------------------------------------------------------------



                                     SUMMARY OF THE CONTRACT 6







------------------------------------------------------------------------------------------------------------------------------------
                           OPTION 1                           OPTION 2                          OPTION 3(3)
------------------------------------------------------------------------------------------------------------------------------------
                                                                                       
GUARANTEED MINIMUM         Not Available                      Not Available                     If certain conditions are met, the
ANNUITY PAYMENTS                                                                                Guaranteed Annuitization Value
                                                                                                may be used to provide guaranteed
                                                                                                minimum annuity payments that
                                                                                                are greater than annuity payments
                                                                                                that would be provided by the
                                                                                                Contract's Fund Value or Cash
                                                                                                Value, as applicable.
------------------------------------------------------------------------------------------------------------------------------------
MINIMUM INITIAL PURCHASE   Qualified Contracts--The minimum   Qualified Contracts--The minimum  Qualified Contracts--the minimum
PAYMENT                    Purchase Payment for Qualified     Purchase Payment for Qualified    Purchase Payment for Qualified
                           Plans is the same for all three    Plans is the same for all three   Plans is the same for all three
                           options. (See "Detailed informa-   options. (See "Detailed infor-    options. (See "Detailed informa-
                           tion about the contract.")         mation about the contract.")      tion about the contract.")
                           Non-Qualified Contracts--$5,000    Non-Qualified Contracts--$10,000  Non-Qualified Contracts--$10,000
------------------------------------------------------------------------------------------------------------------------------------
ANNUITANT ISSUE AGE        Qualified Contracts --0-85         Qualified Contracts--0-79         Qualified Contracts--0-79
                           Non-Qualified Contracts --0-85     Non-Qualified Contracts--0-79     Non-Qualified Contracts--0-79
------------------------------------------------------------------------------------------------------------------------------------
ANNUAL CONTRACT CHARGE     Current charge is $30.             Current charge is $0.             Current charge is $0.
                           The annual contract charge may     The annual contract charge may    The annual contract charge may be
                           be increased to a maximum of       be increased to a maximum of $50  increased to a maximum of $50
                           $50 ($30 in certain states) on 30  ($30 in certain states) on 30     ($30 in certain states) on 30 days
                           days written notice.               days written notice.              written notice.
------------------------------------------------------------------------------------------------------------------------------------




(1)  In the calculations of the death benefit, for each partial surrender, the
     proportionate reduction is equal to the amount of that partial surrender
     and any surrender charge and any market value adjustment divided by the
     Fund Value immediately before that partial surrender, multiplied by the
     Purchase Payments paid before that partial surrender. Depending on your
     state, for Contracts purchased prior to July 22, 2003, the death benefit is
     the greater of: (1) The Fund Value less any outstanding debt on the date
     due proof of the Annuitant's death is received by the Company, or (2) The
     Purchase Payments paid, less any partial surrenders and their surrender
     charges minus any outstanding debt, and plus or minus any Market Value
     Adjustment.

(2)  The payments and values described in (1) and (2) do not include Purchase
     Payments made during the 12-month period immediately prior to the date due
     proof of death is received by the Company and reflect any partial
     surrenders made including any applicable market value adjustment and
     surrender charge, and less any outstanding debt.

(3)  As of November 29, 2004, Option 3 is no longer available for new business.



7 SUMMARY OF THE CONTRACT



TRANSFER OF FUND VALUE

You may transfer fund value among the subaccounts and to or from the Guaranteed
Interest Account with Market Value Adjustment. Transfers from the Guaranteed
Interest Account with Market Value Adjustment may be subject to a market value
adjustment for Contracts issued in certain states. Transfers may be made by
telephone, facsimile or via the web if the proper form or the
telephone/facsimile/web authorization on a Contract application has been
completed, signed, and received by the Company at its Operations Center.
Transfers by telephone, facsimile or via the web are subject to the Company's
rules and conditions for such privilege. (See "Transfers.")


LOANS

If your Contract permits, you may borrow up to 50% of your Contract's Fund
Value from the Company. Your Contract will be the only security required for
the loan. Contracts issued to 401(k) plans are generally the only Contracts
which permit loans. An amount equal to the amount of the loan is transferred to
the loan account as security for the loan. The loan account is part of the
Company's General Account.

We will charge you interest on the amount borrowed. If you do not pay the
interest when due, the amount due plus any accrued interest will be added to
the outstanding debt.


SURRENDERS

You may surrender all or part of the Contract at any time and receive its Cash
Value while the Annuitant is alive prior to the annuity starting date. We may
impose a surrender charge and market value adjustment (if applicable). A
partial surrender may reduce your death benefit proportionately by the same
percentage that the surrender (including any surrender charge and any market
value adjustment, if applicable) reduced Fund Value. The amounts you receive
upon surrender may be subject to income taxes and a 10% penalty tax if you are
younger than 59-1/2 at the time of surrender. (See "Federal tax status.")


CHARGES AND DEDUCTIONS

The Contract provides for the deduction of various charges and expenses from
the fund value of the Contract.

We pay compensation to brokers-dealers who sell the Contracts. (For a
discussion of this compensation, see "Distribution of the contracts.")


RIGHT TO RETURN CONTRACT PROVISION

This information is no longer applicable, as these Contracts are no longer
available to new purchasers.

You have the right to examine the Contract when you receive it. You may return
the Contract for any reason during the right to return contract period (usually
within ten days from the day you receive it). You will receive the Purchase
Payments received by the Company, less any partial surrenders you make. During
the "right to return contract period," Purchase Payments will be retained in
the Company's General Account and will earn interest at a rate not less than
3.50% per year. If you have not returned the Contract at the end of the right
to return contract period, we transfer the Net Purchase Payments with interest
to the subaccounts and/or the Guaranteed Interest Account.


DEATH BENEFIT


If the Annuitant (and the Secondary Annuitant, if any) dies before the annuity
starting date, the Company will pay a death benefit to the Beneficiary. The
death benefit will depend upon the benefit option package in effect on the date
the Annuitant dies. If the Annuitant dies after annuity payments start, no
death benefit is payable except as may be payable under the settlement option
selected. (See "Death benefit.")


--------------------------------------------------------------------------------
ANNUITANT -- The person upon whose continuation of life any annuity payment
depends.
SECONDARY ANNUITANT -- The party designated by the Owner to become the
Annuitant, subject to certain conditions, on the death of the Annuitant.
BENEFICIARY -- The party entitled to receive benefits payable at the death of
the Annuitant or (if applicable) the Secondary Annuitant.
ANNUITY STARTING DATE -- Attainment of age 95, or at the discretion of the
Owner of the Contract, an earlier date that is at least ten years from the
Effective Date of the Contract.
--------------------------------------------------------------------------------


                                                      SUMMARY OF THE CONTRACT  8



FEE TABLES


The following tables describe the fees and expenses that you will pay when
buying, owning, and surrendering the contract.

The first table describes the fees and expenses that you will pay at the time
that you buy the Contract, surrender the Contract, or transfer fund value
between investment options or, for Contracts funding 401(k) plans only, take a
loan. A charge for taxes may also be deducted. For the table of fees applicable
to Contracts issued in the State of Washington, see Appendix I.




------------------------------------------------------------------------------------------------------------------------------------
 OWNER TRANSACTION EXPENSES:
------------------------------------------------------------------------------------------------------------------------------------
                                                                             
Maximum deferred sales load (surrender charge)                                   7.00%(1)
(as a percentage of Fund Value surrendered)
------------------------------------------------------------------------------------------------------------------------------------
Loan interest spread (effective annual rate)                                     2.50%(2)
------------------------------------------------------------------------------------------------------------------------------------
Maximum transfer charge                                                          $25(3)
------------------------------------------------------------------------------------------------------------------------------------
The next table describes the fees and expense that you will pay periodically during the time that you own the Contract, not
including Fund portfolio company fees and expenses.
------------------------------------------------------------------------------------------------------------------------------------
Maximum annual contract charge                                                   $50(4)
------------------------------------------------------------------------------------------------------------------------------------
 SEPARATE ACCOUNT ANNUAL EXPENSES (AS A PERCENTAGE OF AVERAGE ANNUAL FUND VALUE IN MONY AMERICA VARIABLE ACCOUNT A):
------------------------------------------------------------------------------------------------------------------------------------
 OPTION 1
------------------------------------------------------------------------------------------------------------------------------------
  Maximum mortality and expense risk fees                                        1.40%(5)
------------------------------------------------------------------------------------------------------------------------------------
  Total separate account annual expenses                                         1.40%(5)
------------------------------------------------------------------------------------------------------------------------------------
 OPTION 2
------------------------------------------------------------------------------------------------------------------------------------
  Maximum mortality and expense risk fees                                        1.95%(6)
------------------------------------------------------------------------------------------------------------------------------------
  Total separate account annual expenses                                         1.95%(6)
------------------------------------------------------------------------------------------------------------------------------------
 OPTION 3(7)
------------------------------------------------------------------------------------------------------------------------------------
  Maximum mortality and expense risk fees                                        2.80%(8)
------------------------------------------------------------------------------------------------------------------------------------
  Total separate account annual expenses                                         2.80%(8)
------------------------------------------------------------------------------------------------------------------------------------



(1)  The surrender charge percentage, which reduces to zero, is determined by
     the Contract Year in which the surrender occurs. The surrender charge may
     be reduced under certain circumstances which include reduction in order to
     guarantee that certain amounts may be received free of the surrender
     charge. (See "Charges against fund value -- Free partial surrender
     amount.")


(2)  The loan interest spread is the difference between the amount of interest
     we charge on loans and the amount of interest we credit to amounts held in
     the loan account to secure loans.

(3)  The transfer charge currently is $0. However, the Company has reserved the
     right to impose a charge for each transfer which will not exceed $25
     (except for contracts issued in the states of South Carolina and Texas,
     where it will not exceed $10). (See "Deductions from fund value -- Transfer
     charge.")

(4)  The annual contract charge for Option 1 is currently $30. The annual
     contract charge for Option 2 and Option 3 is currently $0. However, the
     Company may in the future change the amount of the charge to an amount not
     exceeding $50 per Contract Year (except for Contracts issued in Maryland,
     Massachusetts, New Jersey, Oklahoma, Oregon, Pennsylvania, South Carolina,
     Texas and Washington where the charge may not exceed $30). (See "Deductions
     from fund value -- Annual contract charge.")

(5)  The mortality and expense risk charge is deducted daily equivalent to a
     current annual rate of 1.20% (and is guaranteed not to exceed a daily rate
     equivalent to an annual rate of 1.40%) from the value of the net assets of
     MONY America Variable Account A.

(6)  The mortality and expense risk charge is deducted daily equivalent to a
     current annual rate of 1.70% (and is guaranteed not to exceed a daily rate
     equivalent to an annual rate of 1.95%) from the value of the net assets of
     MONY America Variable Account A.

(7)  As of November 29, 2004, Option 3 is no longer available for new business.

(8)  The mortality and expense risk charge is deducted daily equivalent to a
     current annual rate of 2.35% (and is guaranteed not to exceed a daily rate
     equivalent to an annual rate of 2.80%) from the value of the net assets of
     MONY America Variable Account A.



The next item shows the minimum and maximum total operating expenses charged by
the portfolio companies for the year ended December 31, 2010. You may pay
portfolio company operating expenses periodically during the time that you own
the Contract. Certain variable investment options invest in a corresponding
portfolio of one of the Trusts or other unaffiliated investment companies. Each
portfolio, in turn, invests in shares of other portfolios of the Trusts and/or
shares of unaffiliated portfolios ("underlying portfolios"). More detail
concerning each Fund portfolio company's fees and expenses is contained in the
prospectus for each portfolio.


9 SUMMARY OF THE CONTRACT







------------------------------------------------------------------------------------------------------------------------------------
 TOTAL ANNUAL FUND OPERATING EXPENSES:                                     LOWEST                HIGHEST
------------------------------------------------------------------------------------------------------------------------------------
                                                                                           
Total Annual Portfolio Operating Expenses for 2010 (expenses that are       0.37%                 1.78%
deducted from portfolio assets including management fees, 12b-1 fees,
service fees, and/or other expenses)(1)
------------------------------------------------------------------------------------------------------------------------------------




(1)  "Total Annual Portfolio Operating Expenses" are based, in part, on
     estimated amounts for options added during the fiscal year 2010 and for the
     underlying portfolios. In addition, the "Minimum" represents the total
     annual operating expenses of the EQ/Small Company Index. The "Maximum"
     represents the total annual operating expenses of the ProFund VP UltraBull
     Portfolio.



EXAMPLE


This example is intended to help you compare the cost of investing in the
contract with the cost of investing in other variable annuity contracts. These
costs include Owner transaction expenses, contract fees, separate account
annual expense, and Fund fees and expenses for the year ended December 31,
2010.


The example assumes that you invest $10,000 in the Contract for the time
periods indicated. The example also assumes that your investment has a 5%
return each year. The example assumes the maximum contract charges and annual
expenses of any of the Fund portfolios (before expense limitations) set forth
in the previous charts. Although your actual costs may be higher or lower,
based on these assumptions, your costs would be:

1. a. If you surrender your Contract at the end of the applicable time
      period (assuming maximum fees and expenses of any of the Fund portfolios):

      --------------------------------------------------------------------------
                       1 YEAR         3 YEARS        5 YEARS       10 YEARS
      --------------------------------------------------------------------------
      Option 1         $1,009         $1,689         $2,383         $3,932

      Option 2         $1,059         $1,837         $2,624         $4,396

      Option 3         $1,137         $2,061         $2,983         $5,060
      --------------------------------------------------------------------------

   b. If you surrender your Contract at the end of the applicable time period
      (assuming minimum fees and expenses of any of the Fund portfolios):


      --------------------------------------------------------------------------
                       1 YEAR         3 YEARS        5 YEARS       10 YEARS
      --------------------------------------------------------------------------
      Option 1         $  877         $1,296         $1,731         $2,605

      Option 2         $  929         $1,451         $1,991         $3,147

      Option 3         $1,008         $1,686         $2,378         $3,924
      --------------------------------------------------------------------------


2. a. If you do not surrender your Contract (assuming maximum fees and expenses
      of any of the Fund portfolios):

      --------------------------------------------------------------------------
                       1 YEAR         3 YEARS        5 YEARS       10 YEARS
      --------------------------------------------------------------------------
      Option 1           $370         $1,126         $1,902         $3,932

      Option 2           $425         $1,284         $2,156         $4,396

      Option 3           $508         $1,522         $2,535         $5,060
      --------------------------------------------------------------------------

   b. If you do not surrender your Contract (assuming minimum fees and expenses
      of any of the Fund portfolios):


      --------------------------------------------------------------------------
                       1 YEAR         3 YEARS        5 YEARS       10 YEARS
      --------------------------------------------------------------------------
      Option 1           $230         $  709         $1,215         $2,605

      Option 2           $285         $  874         $1,489         $3,147

      Option 3           $369         $1,123         $1,897         $3,924
      --------------------------------------------------------------------------


3. a. If you annuitize your Contract and the proceeds are settled under
      Settlement Options 3 or 3A (life income with annuity options) (assuming
      maximum fees and expenses of any of the Fund portfolios):

      --------------------------------------------------------------------------
                       1 YEAR         3 YEARS        5 YEARS       10 YEARS
      --------------------------------------------------------------------------
      Option 1         $1,009         $1,126         $1,902         $3,932

      Option 2         $1,059         $1,284         $2,156         $4,396

      Option 3         $1,137         $1,522         $2,535         $5,060
      --------------------------------------------------------------------------

   b. If you annuitize your Contract and the proceeds are settled under
      Settlement Options 3 or 3A (life income with annuity options) (assuming
      minimum fees and expenses of any of the Fund portfolios):


      --------------------------------------------------------------------------
                       1 YEAR         3 YEARS        5 YEARS       10 YEARS
      --------------------------------------------------------------------------
      Option 1         $  877         $  709         $1,215         $2,605

      Option 2         $  929         $  874         $1,489         $3,147

      Option 3         $1,008         $1,123         $1,897         $3,924
      --------------------------------------------------------------------------


                                                      SUMMARY OF THE CONTRACT 10



4. a. If you annuitize your Contract and the proceeds are settled under
      Settlement Options 1, 2 or 4 (annuity income without life contingencies)
      (assuming maximum fees and expenses of any of the Fund portfolios):

      --------------------------------------------------------------------------
                       1 YEAR         3 YEARS        5 YEARS       10 YEARS
      --------------------------------------------------------------------------
      Option 1         $1,009         $1,689         $2,383         $3,932

      Option 2         $1,059         $1,837         $2,624         $4,396

      Option 3         $1,137         $2,061         $2,983         $5,060
      --------------------------------------------------------------------------

   b. If you annuitize your Contract and the proceeds are settled under
      Settlement Options 1, 2 or 4 (annuity income without life contingencies)
      (assuming minimum fees and expenses of any of the Fund portfolios):



      --------------------------------------------------------------------------
                       1 YEAR         3 YEARS        5 YEARS       10 YEARS
      --------------------------------------------------------------------------
      Option 1         $  877         $1,296         $1,731         $2,605

      Option 2         $  929         $1,451         $1,991         $3,147

      Option 3         $1,008         $1,686         $2,378         $3,924
      --------------------------------------------------------------------------


For the purposes of the Fee Tables and the Example, we assume that the Contract
is owned during the accumulation period. (See "Charges and Deductions.") On and
after the annuity starting date, different fees and charges will apply.


OTHER CONTRACTS


We offer a variety of fixed and variable annuity contracts. They may offer
features, including investment options, fees and/or charges that are different
from those in the Contracts offered by this prospectus. Not every Contract is
offered through the same distributor. Upon request, your registered
representative can show you information regarding other annuity Contracts that
he or she distributes. You can also contact us to find out more about any MONY
Life Insurance Company of America annuity Contracts.



CONDENSED FINANCIAL INFORMATION


Please see Appendix II at the end of this prospectus for the unit values and
the number of units outstanding as of the end of the period shown for each of
the variable investment options available as of December 31, 2010.


11 SUMMARY OF THE CONTRACT



2. WHO IS MONY LIFE INSURANCE COMPANY OF AMERICA?


--------------------------------------------------------------------------------

MONY LIFE INSURANCE COMPANY OF AMERICA

We are MONY Life Insurance Company of America (the "Company"), an Arizona stock
life insurance corporation organized in 1969. The Company is an indirect,
wholly-owned subsidiary of AXA Financial, Inc., a holding company, which is
itself an indirect, wholly-owned subsidiary of AXA SA ("AXA"). AXA is a French
holding company for an international group of insurance and related financial
services companies. As the ultimate sole shareholder of the Company, and under
its other arrangements with the Company and parent, AXA exercises significant
influence over the operations and capital structure of the Company and its
parent. AXA holds its interest in the Company through a number of other
intermediate holding companies, including Oudinot Participations, AXA America
Holdings, Inc., AXA Equitable Financial Services, LLC, and MONY Life Insurance
Company, a life insurance company. The Company is obligated to pay all amounts
that are promised to be paid under the contracts. No company other than the
Company, however, has any legal responsibility to pay amounts that the Company
owes under the contracts.


AXA Financial, Inc. and its consolidated subsidiaries managed approximately
$575.3 billion in assets as of December 31, 2010. The Company is licensed to
sell life insurance and annuities in forty-nine states (not including New
York), the District of Columbia, the U.S. Virgin Islands and Puerto Rico. Our
home office is located at 1290 Avenue of the Americas, New York, NY 10104.


HOW TO REACH US

To obtain (1) any forms you need for communicating with us, (2) unit values and
other values under your policy, and (3) any other information or materials that
we provide in connection with your Contract or the Portfolios, you may
communicate with our processing office as listed below for the purposes
described. Please refer to "Telephone/  Fax/Web Transactions" for effective
dates for processing telephone, Internet, and facsimile requests, later in this
prospectus. Certain methods of contacting us, such as by telephone or
electronically may be unavailable or delayed (for example our fax service may
not be available at all times and/or we may be unavailable due to emergency
closing). In addition, the level and type of service available may be
restricted based on criteria established by us. In order to avoid delays in
processing, please send your correspondence and check to the appropriate
location, as follows:



--------------------------------------------------------------------------------
 FOR CORRESPONDENCE WITH CHECKS:
--------------------------------------------------------------------------------

FOR SUBSEQUENT CONTRIBUTIONS SENT BY REGULAR MAIL:

     MONY Life Insurance Company of America
     P.O. Box 5064
     New York, NY 10087-5064

FOR SUBSEQUENT CONTRIBUTIONS SENT BY EXPRESS DELIVERY:

     JPMorgan Chase - Lockbox Processing
     Lockbox - MONY Life Insurance Company of America - LBX 5064
     4 Chase Metrotech Center
     7th Floor East
     Brooklyn, NY 11245




--------------------------------------------------------------------------------
 FOR CORRESPONDENCE WITH CHECKS:
--------------------------------------------------------------------------------
FOR ALL OTHER COMMUNICATIONS (E.G., REQUESTS FOR TRANSFERS, WITHDRAWALS, OR
REQUIRED NOTICES) SENT BY MAIL:


     MONY Life Insurance Company of America
     Policyholder Services
     100 Madison Street
     Syracuse, New York 13202

Your correspondence will be picked up at the mailing address noted above and
delivered to our processing office. Your correspondence, however, is not
considered received by us until it is received at our processing office. Where
this prospectus refers to the day when we receive a contribution, request,
election, notice, transfer or any other transaction request from you, we mean
the day on which that item (or the last thing necessary for us to process that
item) arrives in complete and proper form at our processing office or via the
appropriate telephone or fax number if the item is a type we accept by those
means. There are two main exceptions: if the item arrives (1) on a day that is
not a business day or (2) after the close of a business day, then, in each
case, we are deemed to have received that item on the next business day. Our
processing office is: 100 Madison Street, Syracuse, New York 13202.

--------------------------------------------------------------------------------
 BY TOLL-FREE PHONE:
--------------------------------------------------------------------------------
Customer service representatives are available weekdays from 9:00 a.m. to 5:00
p.m. Eastern Time at 1-800-487-6669.

--------------------------------------------------------------------------------
 BY INTERNET:
--------------------------------------------------------------------------------
Clients may access Online Account Access by visiting our Website at
www.axa-equitable.com. Our Website provides access to account information and
customer service. After enrolling and setting up a password, you can view
account details, perform certain transactions, print customer service forms and
find answers to Frequently Asked Questions (FAQs).

You can also change your allocation percentages, transfer among investment
options, make a payment, and/or change your address (1) by toll-free phone, (2)
over the Internet, through Online Account Access, or (3) by writing our
Operations Center. For more information about the transaction requests you can
make by phone, fax or internet, see "Telephone/fax/web transactions" later in
this prospectus.


MONY AMERICA VARIABLE ACCOUNT A

MONY America Variable Account A is a separate investment account of the
Company. Presently, only Purchase Payments for individual flexible payment
variable annuity contracts are permitted to be allocated to MONY America
Variable Account A. The assets in MONY America Variable Account A are kept
separate from the General Account assets and other separate accounts of the
Company.

The Company owns the assets in MONY America Variable Account A. The Company is
required to keep assets in MONY America Variable Account A that equal the total
market value of the contract liabilities funded by MONY America Variable
Account A. Realized or unrealized


                              WHO IS MONY LIFE INSURANCE COMPANY OF AMERICA?  12



income gains or losses of MONY America Variable Account A are credited or
charged against MONY America Variable Account A assets without regard to the
other income, gains or losses of the Company. Reserves and other liabilities
under the contracts are assets of MONY America Variable Account A. MONY America
Variable Account A assets are not chargeable with liabilities of the Company's
other businesses. The assets of MONY America Variable Account A are, however,
available to cover the liabilities of our General Account to the extent that
the assets of MONY America Variable Account A exceed the liabilities of the
contracts supported by it. The amount of some of our obligations under the
Contracts is based on the assets in MONY America Variable Account A. However,
the obligations themselves are obligations of the Company.

MONY America Variable Account A was authorized by the Board of Directors of the
Company and established under Arizona law on March 27, 1987. MONY America
Variable Account A is registered under the Investment Company Act of 1940 ("the
1940 Act") and is registered and classified under that act as a "unit
investment trust". The SEC, however, does not manage or supervise the Company
or MONY America Variable Account A. Although MONY America Variable Account A is
registered, the Securities and Exchange Commission (the "SEC") does not monitor
the activity of MONY America Variable Account A on a daily basis. The Company
is not required to register, and is not registered, as an investment company
under the 1940 Act. A unit investment trust is a type of investment company.
For state law purposes, MONY America Variable Account A is treated as a part or
division of the Company.

MONY America Variable Account A is divided into subdivisions called
subaccounts. Each subaccount invests only in shares of a designated portfolio
of the Funds. For example, the EQ/Core Bond Index Subaccount invests solely in
shares of the EQ Advisors Trust EQ/Core Bond Index Portfolio. These portfolios
serve only as the underlying investment for variable annuity and variable life
insurance contracts issued through separate accounts of the Company or other
life insurance companies. The portfolios may also be available to certain
pension accounts. The portfolios are not available directly to individual
investors. Income and realized and unrealized gains or losses from assets of
each subaccount are credited to or charged against that subaccount without
regard to income, gains or losses in the other subaccounts, our General
Account, or any other separate accounts. We reserve the right to credit or
charge a subaccount in a different manner if required, or appropriate, by
reason of a change in the law. In the future, we reserve the right, in
compliance with the laws that apply, to establish additional subaccounts;
eliminate subaccounts; combine two or more subaccounts; transfer the assets we
determine to be the shares of the class of contracts to which the contracts
belong from any subaccount to another subaccount; restrict or eliminate any
voting rights as to the MONY America Variable Account A; and cause one or more
subaccounts to invest some or all of their assets in one or more other trusts
or investment companies of MONY America Variable Account A if marketing needs,
tax conditions or investment conditions warrant. Future subaccounts may invest
in other portfolios of the Funds or in other securities, as permitted by
applicable law. Any new subaccounts may be made available to existing contracts
on a basis to be determined by us. If any of these changes are made, we may, by
appropriate endorsement, change the Contract to reflect the change.


13  WHO IS MONY LIFE INSURANCE COMPANY OF AMERICA?



3. THE FUNDS


--------------------------------------------------------------------------------

Each available subaccount of MONY America Variable Account A will invest only
in the shares of the Funds. We offer both affiliated and unaffiliated Funds,
which in turn offer one or more portfolios. There is a separate subaccount
which corresponds to each portfolio of a Fund offered under the Contract. AXA
Equitable Funds Management Group, LLC, a wholly owned subsidiary of AXA
Equitable, serves as the investment manager of the portfolios of AXA Premier
VIP Trust and EQ Advisors Trust. For some portfolios, AXA Equitable Funds
Management Group, LLC has entered into sub-advisory agreements with investment
advisers (the "sub-advisers") to carry out the day-to-day investment decisions
for the portfolios. As such, AXA Equitable Funds Management Group, LLC oversees
the activities of the sub-advisers with respect to the Trusts and is
responsible for retaining or discontinuing the services of those sub-advisers.
The chart below indicates the sub-adviser(s) for each portfolio, if any. The
chart below also shows the currently available portfolios and their investment
objectives.

You should be aware that AXA Advisors, LLC and AXA Distributors, LLC (together,
the "Distributors") receive 12b-1 fees from affiliated portfolios for providing
certain distribution and/or shareholder support services. These fees will not
exceed 0.25% of the portfolios' average daily net assets. The affiliated
portfolios' sub-advisers and/or their affiliates also contribute to the cost of
expenses for sales meetings or seminar sponsorships that may relate to the
policies and/or the sub-advisers' respective portfolios. It may be more
profitable for us to offer affiliated portfolios than to offer unaffiliated
portfolios.

The Funds are registered with the SEC under the 1940 Act. The Funds, or any of
them, may withdraw from sale any or all the respective portfolios as allowed by
applicable law. Not all Funds may be available in all states or in all markets.


AXA Equitable or the Distributors may directly or indirectly receive 12b-1 fees
and additional payments from certain unaffiliated portfolios, their advisers,
sub-advisers, distributors or affiliates, for providing certain administrative,
marketing, distribution and/or shareholder support services. These fees and
payments range from 0% to 0.60% of the unaffiliated portfolios' average daily
net assets. The Distributors may also receive payments from the advisers or
sub-advisers of the unaffiliated portfolios or their affiliates for certain
distribution services, including expenses for sales meetings or seminar
sponsorships that may relate to the contracts and/or the advisers' respective
portfolios.

As a contract owner, you may bear the costs of some or all of these fees and
payments through your indirect investment in the portfolios. (See the
portfolios' prospectuses for more information.) These fees and payments will
reduce the underlying portfolios' investment returns. AXA Equitable may profit
from these fees and payments.

AXA Equitable considers the availability of these fees and payment arrangements
during the selection process for the underlying portfolios. These fees and
payment arrangements may create an incentive for us to select portfolios (and
classes of shares of portfolios) that pay us higher amounts.

You should note that some portfolios have objectives and strategies that are
substantially similar to those of certain funds that are purchased directly
rather than under a variable insurance product such as the Contract. These
portfolios may even have the same manager(s) and/or a similar name. However,
there are numerous factors that can contribute to differences in performance
between two investments, particularly over short periods of time. Such factors
include fees; the timing of stock purchases and sales; differences in fund cash
flows; and specific strategies employed by the portfolio manager.

The AXA Allocation Portfolios offer contract owners a convenient opportunity to
invest in other portfolios that are managed and have been selected for
inclusion in the AXA Allocation Portfolios by AXA Equitable Life Insurance
Company ("AXA Equitable"), the investment manager of the AXA Premier VIP Trust
and EQ Advisors Trust. AXA Advisors, LLC, an affiliated broker-dealer of the
Company, may promote the benefits of such portfolios to contract owners and/or
suggest, incidental to the sale of this Contract, that contract owners consider
whether allocating some or all of their account value to such portfolios is
consistent with their desired investment objectives. In doing so, AXA
Equitable, and/or its affiliates, may be subject to conflicts of interest
insofar as AXA Equitable may derive greater revenues from the AXA Allocation
Portfolios than certain other portfolios available to you under your Contract.
Please see "Payment and allocation of Purchase Payment" in "Detailed
information about the Contract" for more information about your role in
managing your allocations.






------------------------------------------------------------------------------------------------------------------------------------
AXA PREMIER VIP TRUST                                                                     INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                   SHARE CLASS   OBJECTIVE                                  AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
                                                                                 
AXA AGGRESSIVE ALLOCATION(1)     Class B       Seeks long-term capital appreciation.      o   AXA Equitable Funds Management
                                                                                              Group, LLC
------------------------------------------------------------------------------------------------------------------------------------
AXA CONSERVATIVE ALLOCATION(1)   Class B       Seeks a high level of current income.      o   AXA Equitable Funds Management
                                                                                              Group, LLC
------------------------------------------------------------------------------------------------------------------------------------
AXA CONSERVATIVE-PLUS            Class B       Seeks current income and growth of capi-   o   AXA Equitable Funds Management
 ALLOCATION(1)                                 tal, with a greater emphasis on current        Group, LLC
                                               income.
------------------------------------------------------------------------------------------------------------------------------------
AXA MODERATE ALLOCATION(1)       Class B       Seeks long-term capital appreciation and   o   AXA Equitable Funds Management
                                               current income.                                Group, LLC
------------------------------------------------------------------------------------------------------------------------------------



                                                                   THE FUNDS  14







------------------------------------------------------------------------------------------------------------------------------------
AXA PREMIER VIP TRUST                                                                    INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME              SHARE CLASS   OBJECTIVE                                      AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
                                                                                
AXA MODERATE-PLUS           Class B       Seeks long-term capital appreciation and       o   AXA Equitable Funds Management
 ALLOCATION(1)                            current income, with a greater emphasis            Group, LLC
                                          on capital appreciation.
------------------------------------------------------------------------------------------------------------------------------------
MULTIMANAGER MULTI-SECTOR   Class A       Seeks high total return through a combi-       o   Pacific Investment Management Company
 BOND                                     nation of current income and capital               LLC
                                          appreciation.
                                                                                         o   Post Advisory Group, LLC

                                                                                         o   SSgA Funds Management, Inc.
------------------------------------------------------------------------------------------------------------------------------------
MULTIMANAGER SMALL CAP      Class B       Seeks long-term growth of capital.             o   AXA Equitable
 GROWTH
                                                                                         o   BlackRock Investment Management, LLC

                                                                                         o   Morgan Stanley Investment Management,
                                                                                             LLC

                                                                                         o   NorthPointe Capital, LLC

                                                                                         o   Wells Capital Management Inc.
------------------------------------------------------------------------------------------------------------------------------------
EQ ADVISORS TRUST                                                                         INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                 SHARE CLASS   OBJECTIVE                                    AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
                                                                                 
ALL ASSET ALLOCATION            Class IB     Seeks long-term capital appreciation and     o   AXA Equitable Funds Management
                                             current income.                                  Group, LLC
------------------------------------------------------------------------------------------------------------------------------------
EQ/ALLIANCEBERNSTEIN SMALL      Class IA     Seeks to achieve long-term growth of         o   AllianceBernstein L.P.
 CAP GROWTH                                  capital.
------------------------------------------------------------------------------------------------------------------------------------
EQ/BLACKROCK BASIC VALUE        Class IB     Seeks to achieve capital appreciation and    o   BlackRock Investment Management, LLC
 EQUITY                                      secondarily, income.
------------------------------------------------------------------------------------------------------------------------------------
EQ/BOSTON ADVISORS EQUITY       Class IB     Seeks a combination of growth and            o   Boston Advisors, LLC
 INCOME                                      income to achieve an above-average and
                                             consistent total return.
------------------------------------------------------------------------------------------------------------------------------------
EQ/CALVERT SOCIALLY             Class IB     Seeks to achieve long-term capital appre-    o   Bridgeway Capital Management, Inc.
 RESPONSIBLE                                 ciation.                                     o   Calvert Investment Management, Inc.
------------------------------------------------------------------------------------------------------------------------------------
EQ/CAPITAL GUARDIAN RESEARCH    Class IA     Seeks to achieve long-term growth of         o   Capital Guardian Trust Company
                                             capital.
------------------------------------------------------------------------------------------------------------------------------------
EQ/CORE BOND INDEX              Class IA     Seeks to achieve a total return before       o   SSgA Funds Management, Inc.
                                             expenses that approximates the total
                                             return performance of the Barclays Capital
                                             Intermediate U.S. Government/Credit
                                             Index, including reinvestment of dividends,
                                             at a risk level consistent with that of the
                                             Barclays Capital Intermediate U.S.
                                             Government/Credit Index.
------------------------------------------------------------------------------------------------------------------------------------
EQ/GAMCO MERGERS AND            Class IB     Seeks to achieve capital appreciation.       o   GAMCO Asset Management, Inc.
 ACQUISITIONS
------------------------------------------------------------------------------------------------------------------------------------
EQ/GAMCO SMALL COMPANY          Class IB     Seeks to maximize capital appreciation.      o   GAMCO Asset Management, Inc.
 VALUE
------------------------------------------------------------------------------------------------------------------------------------
EQ/GLOBAL MULTI-SECTOR EQUITY   Class IA     Seeks to achieve long-term capital appre-    o   AXA Equitable Funds Management
                                             ciation.                                         Group, LLC
                                                                                          o   BlackRock Investment Management, LLC

                                                                                          o   Morgan Stanley Investment Management
                                                                                              Inc.
------------------------------------------------------------------------------------------------------------------------------------



15 THE FUNDS







------------------------------------------------------------------------------------------------------------------------------------
EQ ADVISORS TRUST                                                                          INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                 SHARE CLASS   OBJECTIVE                                     AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
                                                                                 
EQ/INTERMEDIATE GOVERNMENT    Class IA       Seeks to achieve a total return before        o   SSgA Funds Management, Inc.
 BOND INDEX                                  expenses that approximates the total
                                             return performance of the Barclays Capital
                                             Intermediate U.S. Government Bond Index,
                                             including reinvestment of dividends, at a
                                             risk level consistent with that of the
                                             Barclays Capital Intermediate U.S. Govern-
                                             ment Bond Index.
------------------------------------------------------------------------------------------------------------------------------------
EQ/LARGE CAP VALUE INDEX(2)   Class IA       Seeks to achieve a total return before        o   SSgA Funds Management, Inc.
                                             expenses that approximates the total
                                             return performance of the Russell 1000
                                             Value Index, including reinvestment of
                                             dividends, at a risk level consistent with
                                             that of the Russell 1000 Value Index.
------------------------------------------------------------------------------------------------------------------------------------
EQ/LARGE CAP VALUE PLUS       Class IA       Seeks to achieve long-term growth of          o   AllianceBernstein L.P.
                                             capital.
                                                                                           o   AXA Equitable Funds Management
                                                                                               Group, LLC
------------------------------------------------------------------------------------------------------------------------------------
EQ/LORD ABBETT GROWTH AND     Class IA       Seeks to achieve capital appreciation and     o   Lord, Abbett & Co. LLC
 INCOME (3)                                  growth of income without excessive fluc-
                                             tuation in market value.
------------------------------------------------------------------------------------------------------------------------------------
EQ/MID CAP INDEX              Class IA       Seeks to achieve a total return before        o   SSgA Funds Management, Inc.
                                             expenses that approximates the total
                                             return performance of the S&P Mid Cap
                                             400 Index, including reinvestment of divi-
                                             dends, at a risk level consistent with that
                                             of the S&P Mid Cap 400 Index.
------------------------------------------------------------------------------------------------------------------------------------
EQ/MID CAP VALUE PLUS         Class IA       Seeks to achieve long-term capital appre-     o   AXA Equitable Funds Management
                                             ciation.                                          Group, LLC

                                                                                           o   BlackRock Investment Management, LLC

                                                                                           o   Wellington Management Company, LLP
------------------------------------------------------------------------------------------------------------------------------------
EQ/MONEY MARKET               Class IA       Seeks to obtain a high level of current       o   The Dreyfus Corporation
                                             income, preserve its assets and maintain
                                             liquidity.
------------------------------------------------------------------------------------------------------------------------------------
EQ/MONTAG & CALDWELL          Class IB       Seeks to achieve capital appreciation.        o   Montag & Caldwell, LLC
 GROWTH
------------------------------------------------------------------------------------------------------------------------------------
EQ/MORGAN STANLEY MID CAP     Class IA       Seeks to achieve capital growth.              o   Morgan Stanley Investment Management
 GROWTH                                                                                        Inc.
------------------------------------------------------------------------------------------------------------------------------------
EQ/PIMCO ULTRA SHORT BOND     Class IB       Seeks to generate a return in excess of       o   Pacific Investment Management
                                             traditional money market products while           Company, LLC
                                             maintaining an emphasis on preservation
                                             of capital and liquidity.
------------------------------------------------------------------------------------------------------------------------------------
EQ/SMALL COMPANY INDEX        Class IA       Seeks to replicate as closely as possible     o   AllianceBernstein L.P.
                                             (before the deduction of Portfolio
                                             expenses) the total return of the Russell
                                             2000 Index.
------------------------------------------------------------------------------------------------------------------------------------
EQ/UBS GROWTH AND INCOME      Class IB       Seeks to achieve total return through capi-   o   UBS Global Asset Management
                                             tal appreciation with income as a                 (Americas) Inc.
                                             secondary consideration.
------------------------------------------------------------------------------------------------------------------------------------
FRANKLIN TEMPLETON VARIABLE
INSURANCE PRODUCTS TRUST --
CLASS 2                                                                                    INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                OBJECTIVE                                                    AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
FRANKLIN INCOME SECURITIES    The Fund's investment goal is to maximize income while       o   Franklin Advisers, Inc.
 FUND                         maintaining prospects for capital appreciation.
------------------------------------------------------------------------------------------------------------------------------------




                                                                    THE FUNDS 16







------------------------------------------------------------------------------------------------------------------------------------
FRANKLIN TEMPLETON VARIABLE
INSURANCE PRODUCTS TRUST --
CLASS 2                                                                                   INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                         OBJECTIVE                                          AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
                                                                                    
FRANKLIN RISING DIVIDENDS              Seeks long-term capital appreciation, with         o   Franklin Advisory Services, LLC
 SECURITIES FUND                       preservation of capital as an important
                                       consideration.
------------------------------------------------------------------------------------------------------------------------------------
INVESCO VARIABLE INSURANCE FUNDS --
SERIES I SHARES                                                                           INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                         OBJECTIVE                                          AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
INVESCO VAN KAMPEN V.I. GLOBAL         Seeks long-term capital appreciation by investing  o   Invesco Advisers, Inc. (sub-advised by
 VALUE EQUITY                          primarily in equity securities of issuers              Invesco Asset Management Limited).
                                       throughout the world, including U.S. issuers.
------------------------------------------------------------------------------------------------------------------------------------
INVESCO V.I. GLOBAL HEALTH CARE        The fund's investment objective is capital growth. o   Invesco Advisers, Inc.
 FUND
------------------------------------------------------------------------------------------------------------------------------------
INVESCO V.I. DIVIDEND GROWTH           The fund's investment objective is to provide      o   Invesco Advisers, Inc.
 FUND(4)                               reasonable current income and long-term growth of
                                       income and capital.
------------------------------------------------------------------------------------------------------------------------------------
INVESCO V.I. TECHNOLOGY FUND           The fund's investment objective is capital growth. o   Invesco Advisers, Inc.
------------------------------------------------------------------------------------------------------------------------------------
JANUS ASPEN SERIES --                                                                     INVESTMENT MANAGER (OR SUB-ADVISER(S),
INSTITUTIONAL SHARES                   OBJECTIVE                                          AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
FORTY PORTFOLIO(5)                     Seeks long-term growth of capital.                 o   Janus Capital Management, LLC
------------------------------------------------------------------------------------------------------------------------------------
OVERSEAS PORTFOLIO                     Seeks long-term growth of capital.                 o   Janus Capital Management, LLC
------------------------------------------------------------------------------------------------------------------------------------
MFS(R) VARIABLE INSURANCE TRUST --                                                        INVESTMENT MANAGER (OR SUB-ADVISER(S),
INITIAL CLASS                          OBJECTIVE                                          AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
MFS(R) UTILITIES SERIES                To seek total return.                              o   Massachusetts Financial Services
                                                                                              Company
------------------------------------------------------------------------------------------------------------------------------------
OPPENHEIMER VARIABLE ACCOUNT                                                              INVESTMENT MANAGER (OR SUB-ADVISER(S),
FUNDS -- SERVICE CLASS                 OBJECTIVE                                          AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
OPPENHEIMER GLOBAL                     Seeks long-term capital appreciation.              o   OppenheimerFunds, Inc.
SECURITIES FUND/VA
------------------------------------------------------------------------------------------------------------------------------------
PIMCO VARIABLE INSURANCE TRUST --                                                         INVESTMENT MANAGER (OR SUB-ADVISER(S),
ADMINISTRATIVE CLASS                   OBJECTIVE                                          AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
GLOBAL BOND PORTFOLIO                  Seeks to maximize total return, consistent with    o   Pacific Investment Management
 (UNHEDGED)                            preservation of capital and prudent                    Company, LLC
                                       investment management.
------------------------------------------------------------------------------------------------------------------------------------
PROFUNDS VP                                                                               INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                         OBJECTIVE                                          AS APPLICABLE)
------------------------------------------------------------------------------------------------------------------------------------
PROFUND VP BEAR                        Seeks daily investment results, before fees and    o   ProFund Advisors LLC
                                       expenses, that correspond to the inverse
                                       (opposite) of the daily performance of the S&P
                                       500 Index.
------------------------------------------------------------------------------------------------------------------------------------
PROFUND VP RISING                      Seeks daily investment results, before fees and    o   ProFund Advisors LLC
 RATES OPPORTUNITY                     expenses, that correspond to the one and
                                       one-quarter times (125%) the inverse (opposite) of
                                       the daily price movement of the most recently
                                       issued 30-year U.S. Treasury Bond ("Long Bond").
------------------------------------------------------------------------------------------------------------------------------------
PROFUND VP ULTRABULL                   Seeks daily investment results, before fees and    o   ProFund Advisors LLC
                                       expenses that correspond to twice (200%) the
                                       daily performance of the S&P 500 Index.
------------------------------------------------------------------------------------------------------------------------------------




(1)  The "AXA Allocation" Portfolios

(2)  This Portfolio will become available on or about May 20, 2011.

(3)  Effective on or about May 20, 2011, subject to regulatory and shareholder
     approvals, interests in the EQ/Large Cap Value Index (the "surviving
     option") will replace interests in the EQ/Lord Abbett Growth and Income
     (the "replaced option"). We will move the assets from the replaced option
     into the surviving option on the date of the scheduled merger. The value of
     your interest in the surviving option will be the same as it was in the
     replaced option. We will also automatically direct any contributions made
     to a replaced option to the surviving option. Any allocation election to a
     replaced option will be considered as an allocation election to the
     surviving option.

(4)  On April 1, 2011, the shareholders of the Invesco V.I. Financial Services
     Fund approved the Agreement and Plan of Reorganization (the
     "Reorganization") between Invesco V.I. Financial Services Fund and Invesco
     V.I. Dividend Growth Fund to take place on or about April 29, 2011.
     Accordingly, interests in the Invesco V.I. Dividend Growth Fund (the
     "surviving option") replaced interests in the Invesco V.I. Financial
     Services Fund (the "replaced option"). On the date of the Reorganization,
     we moved the assets from the replaced option into the surviving option. The
     value of your interest in the surviving option is the same as it was in the
     corresponding replaced option. We will also automatically direct any
     contributions made to the replaced option to the surviving option. Any
     allocation election to the replaced option is considered an allocation
     election to the surviving option. Also, until our administrative systems
     are fully updated in June 2011, statements you receive from us may reflect
     the Invesco V.I. Financial Services Fund.



17 THE FUNDS




(5)  Unlike the other Funds, the Janus Aspen Forty Portfolio is a
     nondiversified, open-end management investment company. A nondiversified
     Fund may hold a larger position in a smaller number of securities than a
     diversified Fund. This means that a single security's increase or decrease
     in value may have a greater impact on the return and net asset value of a
     nondiversified Fund than a diversified Fund.



YOU SHOULD CONSIDER THE INVESTMENT OBJECTIVES, RISKS AND CHARGES AND EXPENSES
OF THE PORTFOLIOS CAREFULLY BEFORE INVESTING. SHARE CLASSES, WHERE APPLICABLE,
ARE DEFINED IN THE CORRESPONDING FUND PROSPECTUS. THE PROSPECTUSES FOR THE FUND
CONTAIN THIS AND OTHER IMPORTANT INFORMATION ABOUT THE PORTFOLIOS. THE
PROSPECTUSES SHOULD BE READ CAREFULLY BEFORE INVESTING. IN ORDER TO OBTAIN
COPIES OF FUND PROSPECTUSES THAT DO NOT ACCOMPANY THIS PROSPECTUS, YOU MAY CALL
ONE OF OUR CUSTOMER SERVICE REPRESENTATIVES AT 1-800-487-6669.

Each Owner should periodically review their allocation of Purchase Payments and
Fund Values among the subaccounts and the Guaranteed Interest Account with
Market Value Adjustment in light of their current objectives, the current
market conditions, and the risks of investing in each of the Funds' various
portfolios. A full description of the objectives, policies, restrictions, risks
and expenses for each of the Funds' portfolios can be found in the prospectus
for each of the Funds.

                                                                    THE FUNDS 18



PURCHASE OF PORTFOLIO SHARES BY MONY AMERICA VARIABLE ACCOUNT A

MONY America Variable Account A will buy and redeem shares from the Funds at
net asset value. Shares will be redeemed when needed for the Company to:

o    collect charges under the Contracts;

o    pay Cash Value on full surrenders of the Contracts;

o    fund partial surrenders;

o    provide benefits under the Contracts; or

o    transfer assets from one subaccount to another or between one or more
     subaccounts of MONY America Variable Account A and the Guaranteed Interest
     Account with Market Value Adjustment as requested by Owners.

Any dividend or capital gain distribution received from a portfolio of a Fund
will be:

o    reinvested immediately at net asset value in shares of that portfolio; or

o    kept as assets of the corresponding subaccount.

--------------------------------------------------------------------------------
CASH VALUE -- The Contract's Fund Value, less (1) any applicable surrender
charge, (2) any outstanding debt, and (3) any applicable market value
adjustment.
--------------------------------------------------------------------------------

Shares of the Funds are not sold directly to the general public. They are sold
to the Company, and may be sold to other insurance companies that issue
variable annuity and variable life insurance contracts. In addition, they may
be sold to retirement plans.

When a Fund sells shares in any of its portfolios both to variable annuity and
to variable life insurance company separate accounts, it engages in mixed
funding. When a Fund sells shares in any of its portfolios to separate accounts
of unaffiliated life insurance companies, it engages in shared funding. Each
Fund may engage in mixed and shared funding. Therefore, due to differences in
redemption rates or tax treatment, or other considerations, the interests of
various shareholders participating in a Fund could conflict.

The Boards of Directors or Trustees of each of the Funds monitors the
respective Fund for the existence of material irreconcilable conflict between
the interests of variable annuity Owners and variable life insurance Owners.
The Boards shall report any such conflict to the boards of the Company and its
affiliates. The Boards of Directors of the Company and its affiliates have
agreed to be responsible for reporting any potential or existing mixed and
shared funding conflicts to the Directors and Trustees of each of the relevant
Funds. The Boards of Directors of the Company and its affiliates will remedy
any conflict at their own cost. The remedy may include establishing a new
registered management investment company and segregating the assets underlying
the variable annuity contracts and the variable life insurance contracts.

The investment objectives and policies of certain portfolios are similar to the
investment objectives and policies of other portfolios that may be managed by
the same investment adviser or manager. The investment results of the
portfolios, however, may be higher or lower than the results of such other
portfolios. There can be no assurance, and no representation is made that the
investment results of any of the portfolios will be comparable to the
investment results of any other portfolio, even if the other portfolio has the
same investment adviser or manager, or if the other portfolio has a similar
name.

19  THE FUNDS



4. DETAILED INFORMATION ABOUT THE CONTRACT


--------------------------------------------------------------------------------


The Fund Value in MONY America Variable Account A and in the Guaranteed
Interest Account with Market Value Adjustment provide many of the benefits of
your Contract. The information in this section describes the benefits,
features, charges and major provisions of the Contract and the extent to which
those depend upon the Fund Value, particularly the Fund Value in MONY America
Variable Account A. There may be differences in your Contract such as
differences in fees, charges, and benefits because of the state where we issued
your Contract. We will include any such differences in your Contract. If we
issued your Contract in the State of Washington, please see Appendix I.



PAYMENT AND ALLOCATION OF PURCHASE PAYMENTS



ISSUE AGES


The issue ages for the two benefit option packages available under the Contract
vary as per the table below. The maximum issue age of the Annuitant for Option
1 is 85. The maximum issue age of the Annuitant for Option 2 is 79. For Option
3, it was 79.

--------------------------------------------------------------------------------
                         OPTION 1   OPTION 2   OPTION 3*
--------------------------------------------------------------------------------
Annuitant Issue           0-85       0-79        0-79
Ages
--------------------------------------------------------------------------------
*    As of November 29, 2004, Option 3 is no longer available for new business.



ISSUANCE OF THE CONTRACT


Disclosure regarding contract issuance and minimum initial Purchase Payments is
for informational purposes only. This Contract is no longer available to new
purchasers.

The Contract is between you and the Company. The Contract is not an investment
advisory account, and the Company is not providing any investment advice or
managing the allocations under your Contract. In the absence of a specific
written arrangement to the contrary, you as the owner of the Contract, have the
sole authority to make investment allocations and other decisions under the
Contract. Your AXA Advisors' financial professional is acting as a
broker-dealer registered representative, and is not authorized to act as an
investment advisor or to manage the allocations under your Contract. If your
financial professional is a registered representative with a broker-dealer
other than AXA Advisors, you should speak with him/her regarding any different
arrangements that may apply.

Individuals who want to buy a Contract must:

(1)  complete an application;

(2)  personally deliver the application to

     (a)   a licensed agent of the Company who is also a registered
           representative of AXA Advisors, LLC or AXA Distributors, LLC
           (together, the "Distributors") who act as the principal underwriters
           for the Contracts, or

     (b)   a licensed agent who is also a registered representative of a
           broker dealer which had been authorized by the Distributors to sell
           the Contract; and

(3)  pay the minimum initial Purchase Payment.

If we receive a completed application and all other information necessary for
processing a purchase order at our Operations Center, we will apply your
initial Purchase Payment no later than two Business Days after we receive the
order. While attempting to finish an incomplete application, we may hold your
initial Purchase Payment for no more than five Business Days. If an incomplete
application cannot be completed within those five days, we will inform you of
the reasons, and will return your Purchase Payment immediately (unless you
specifically authorize us to keep it until the application is complete). Once
you complete your application, we must apply the initial Purchase Payment
within two Business Days. We will apply any additional Purchase Payments you
make on the Business Day we receive them at our Operations Center.

The Contract may be used with certain tax qualified plans. The Contract
includes attributes such as tax deferral on accumulated earnings. Qualified
retirement plans provide their own tax deferral benefit; the purchase of this
Contract does not provide additional tax deferral benefits beyond those
provided in the qualified plan. Accordingly, if you are purchasing this
Contract, you should purchase it for its death benefit, annuity benefits, and
other non-tax related benefits. Please consult a tax adviser for information
specific to your circumstances in order to determine whether the Contract is an
appropriate investment for you.

The minimum initial Purchase Payment for individuals varies depending upon the
use of the Contract, the method of purchase and the benefit option package
selected. The chart below shows the minimum initial Purchase Payment for each
situation.

                                     DETAILED INFORMATION ABOUT THE CONTRACT  20






------------------------------------------------------------------------------------------------------------------------------------
 USE OF CONTRACT OR METHOD OF MAKING PURCHASE PAYMENT                               MINIMUM INITIAL PURCHASE PAYMENT
------------------------------------------------------------------------------------------------------------------------------------
                                                                                 
Individual retirement accounts and annuities under Section 408 of the Code (other   $2,000
than Simplified Employee Pensions), including Roth IRAs under Section 408A of
the Code (no longer available to new purchasers).
------------------------------------------------------------------------------------------------------------------------------------
Non-Qualified Contracts (no longer available to new purchasers).                    Option 1 -- $5,000
                                                                                    Option 2 -- $10,000
                                                                                    Option 3 -- $10,000
------------------------------------------------------------------------------------------------------------------------------------
H.R. 10 plans (self-employed individuals' retirement plans under Section 401 of     $  600
the Code) (no longer available to new purchasers) and Simplified Employee Pen-
sions under Section 408 of the Code (no longer available to new purchasers).
------------------------------------------------------------------------------------------------------------------------------------
Certain corporate or association retirement plans.                                  $  600
------------------------------------------------------------------------------------------------------------------------------------
Annuity purchase plans sponsored by certain tax-exempt organizations, govern-       $  600
mental entities and deferred compensation plans under Section 457 of the Code.
------------------------------------------------------------------------------------------------------------------------------------
Payroll deduction and automatic checking account withdrawal plans.                  Annualized rate of $600 (i.e., $600 per
                                                                                    year, $300 semiannually, $150 quarterly or $50
                                                                                    per month)
------------------------------------------------------------------------------------------------------------------------------------
Government Allotment Plans                                                          $50 per month
------------------------------------------------------------------------------------------------------------------------------------


--------------------------------------------------------------------------------
GOVERNMENT ALLOTMENT PLANS -- Payroll deduction plans used for financial
products by government employees.
--------------------------------------------------------------------------------
Additional Purchase Payments may be made at any time--before the annuity
starting date as long as the Annuitant is living. However, for certain
automatic payment plans, the smallest additional payment is $50.

The Company reserves the right to revise its rules from time to time to specify
different minimum Purchase Payments for such plans. In addition, the prior
approval of the Company is needed before it will accept a Purchase Payment if
that would cause Cumulative Purchase Payments, less any partial surrenders and
their surrender charges and market value adjustments, to exceed $1,500,000.

The Company reserves the right to reject an application for any reason
permitted by law.

Net Purchase Payments received before the Effective Date will be held in the
Company's General Account and will be credited with interest at not less than
3.50% per year if:

(1)  the Contract is issued by the Company, and

(2)  the Contract is delivered to the Owner.

No interest will be paid if the Contract is not issued or if it is declined by
the Owner.

These amounts will be held in that account pending end of the right to return
contract period. (See below.)

--------------------------------------------------------------------------------
EFFECTIVE DATE -- The date the contract begins as shown in the Contract.
--------------------------------------------------------------------------------


TAX-FREE 'SECTION 1035' EXCHANGES


This information is no longer applicable to the purchase of these Contracts as
these Contracts are no longer available to new purchasers.

The Owner can generally exchange one annuity contract for another in a
'tax-free exchange' under Section 1035 of the Internal Revenue Code. Similar
rules may apply to changing the funding vehicle in a Qualified Plan. Before
making the exchange, the Owner should compare both contracts carefully.
Remember that if you exchange another contract for the one described in this
prospectus, you might have to pay a surrender charge on the old contract. There
will be a new surrender charge period for this Contract and other charges may
be higher (or lower) and the benefits may be different. If the exchange does
not qualify for Section 1035 treatment, the Owner may have to pay federal
income tax, and penalty taxes on the exchange. The Owner should not exchange
another contract for this one unless he or she determines, after knowing all
the facts, that the exchange is in the Owner's best interest and not just
better for the person trying to sell the Owner this Contract (that person will
generally earn a commission if the Owner buys this Contract through an exchange
or otherwise).



RIGHT TO RETURN CONTRACT PROVISION


This information is no longer applicable as these Contracts are no longer
available to new purchasers.

The Owner may return the Contract during the right to return contract period
(usually within 10 days) of the delivery date. The Contract must be returned to
the Company or any agent of the Company. When the Company receives the
Contract, it will be voided as if it were never in effect. Unless state law
requires otherwise, the amount to be refunded is equal to the Purchase Payments
received by the Company, less any partial surrenders you made. During the right
to return contract period, Purchase Payments will be retained in the Company's
General Account and will earn interest at a rate not less than 3.50% per year.
If you have not returned the Contract at the end of the right to return
contract period, we transfer the Net Purchase Payments with interest to the
subaccounts and/or the Guaranteed Interest Account.



ALLOCATION OF PAYMENTS AND FUND VALUE

ALLOCATION OF PAYMENTS. On the application, the Owner may allocate Net Purchase
Payments to any of the available subaccounts of MONY America Variable Account A
or to the Guaranteed Interest Account with Market Value Adjustment. Net Purchase
Payments (and any interest thereon) are held in the General Account if they are
received before the end of the right to return contract period.


The portion of Net Purchase Payments allocated to the Guaranteed Interest
Account with Market Value Adjustment will be held in the Guaranteed Interest
Account with Market Value Adjustment of the General Account for the specified
period selected and will be credited with interest at the rate declared by the
Company for that specified period. The portion of Net Purchase Payments
allocated to subaccounts of MONY America Variable Account A will earn 3.50%
annual interest until the right to return contract period expires. (See "Right
to


21  DETAILED INFORMATION ABOUT THE CONTRACT



return contract provision" above.) After the right to return Contract period
has expired, the value of Net Purchase Payments allocated to subaccounts of
MONY America Variable Account A will automatically be transferred to MONY
America Variable Account A subaccount(s) according to the Owner's percentage
allocation.

After the right to return contract period, under a non-automatic payment plan,
if the Owner does not:

(1)  specify the amount to be allocated among subaccounts, or

(2)  specify the percentage to be allocated among subaccounts, or

(3)  the amount or percentage specified is incorrect or incomplete,

the Net Purchase Payments will be allocated under the Owner's most recent
instructions on record with the Company. The percentage specified must not be
less than 5% of the Net Purchase Payment. Allocation percentages must total
100%. For automatic payment plans, Net Purchase Payments will be allocated
according to the Owner's most recent instructions on record.

The Owner may change the specified allocation formula for future Net Purchase
Payments at any time without charge by sending written notification to the
Company at the Operations Center. Prior allocation instructions may also be
changed by telephone, facsimile or via the web subject to the rules of the
Company and its right to terminate or modify telephone, facsimile or via the
web allocation. The Company reserves the right to deny any telephone, facsimile
or via the web allocation request. (See "Telephone/fax/web transactions.") Any
such change, whether made in writing or by telephone, facsimile or via the web,
will be effective seven days after we receive notice of the change in
accordance with the requirements of state insurance departments and the
Investment Company Act of 1940.

Contracts issued in Maryland, Massachusetts, New Jersey, Oklahoma, Oregon,
Pennsylvania, South Carolina, Texas and Washington must maintain a minimum Fund
Value balance of $2,500 in the Guaranteed Interest Account with Market Value
Adjustment when an allocation to said account is chosen.



CALCULATING UNIT VALUES FOR EACH SUBACCOUNT


When allocated Net Purchase Payments are received they are credited to
subaccounts of MONY America Variable Account A in the form of units. The number
of units is determined by dividing the dollar amount allocated to a particular
subaccount by the unit value for that subaccount for the Business Day on which
the Purchase Payment is received.

To determine the unit value of a subaccount on each Business Day, the Company
takes the prior Business Day's unit value and multiplies it by the Net
Investment Factor for the current Business Day. The Net Investment Factor is
used to measure the investment performance of a subaccount from one Business
Day to the next. The Net Investment Factor for each subaccount equals:

(1)  the net asset value per share of each Fund held in the subaccount at the
     end of the current Business Day divided by

(2)  the net asset value per share of each Fund held in the subaccount at the
     end of the prior Business day, minus

(3)  the daily mortality and expense risk charge and any other applicable
     charges adjusted for the number of calendar days in the period.

The unit value of these subaccounts may increase, decrease or remain the same
from Business Day to Business Day. The unit value depends on the investment
performance of the portfolio of the Fund in which the subaccount invests and
any expenses and charges deducted from MONY America Variable Account A. The
Owner bears the entire investment risk. Owners should periodically review their
allocations of payments and values in light of market conditions and overall
financial planning requirements.


CALCULATION OF GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT FUND
VALUE


Net Purchase Payments to be allocated to the Guaranteed Interest Account with
Market Value Adjustment will be credited to the Accumulation Period chosen by
the Owner on

(1)  the date received at the Operations Center, or

(2)  if the day Net Purchase Payments are received is not a Business Day, then
     on the next Business Day.

Interest will be credited daily.


CALCULATION OF FUND VALUE


The Contract's Fund Value will reflect:


o    The investment performance of the selected subaccount(s) of MONY America
     Variable Account A.



o    Amounts credited (including interest) to the Guaranteed Interest Account
     with Market Value Adjustment.

o    Any Net Purchase Payments.

o    Any transfer charges.

o    Any partial surrenders.

o    Any outstanding debt.



o    All contract charges (including surrender charges and market value
     adjustments) imposed.


There is no guaranteed minimum Fund Value, except to the extent Net Purchase
Payments have been allocated to the Guaranteed Interest Account with Market
Value Adjustment. Because a Contract's Fund Value at any future date will be
dependent on a number of variables, it cannot be predetermined.

The Fund Value will be computed first on the Effective Date and thereafter on
each Business Day. On the Effective Date, the Contract's Fund Value will be the
Net Purchase Payments received on or before the Effective Date plus any
interest credited on those Payments during the period when Net Purchase
Payments are held in the General Account. (See "Issuance of the Contract".)

After amounts allocated to the subaccounts are transferred from the General
Account to MONY America Variable Account A, on each Business Day, the
Contract's Fund Value will be computed as follows:


(1)  Determine the aggregate of the Fund Values attributable to the Contract in
     each of the subaccounts on that Business Day. This is done by multiplying
     the subaccount's unit value on that date by the number of subaccount units
     allocated to the Contract. The computation of the Contract's Fund Value in
     the subaccount is done before any other Contract transactions on that
     Business Day.

(2)  Add any amount credited to the Guaranteed Interest Account with Market
     Value Adjustment before that Business Day. This amount is the aggregate of
     all Net Purchase Payments allocated to the Guaranteed Interest Account with
     Market Value Adjustment and:



                                     DETAILED INFORMATION ABOUT THE CONTRACT  22




     o    The addition of any interest credited.

     o    Addition or subtraction of any amounts transferred.

     o    Subtraction of any partial surrenders.

     o    Subtraction of any contract charges, surrender charges, transfer
          charges, and any Market Value Adjustments



(3)  Add the value held in the loan account to secure contract loans and
     interest credited on that day on that amount;

(4)  Add any Net Purchase Payment received on that Business Day;

(5)  Subtract any partial surrender amount (reflecting any surrender charge and
     Market Value Adjustment) made on that Business Day;

(6)  Subtract any annual contract charge and/or transfer charge deductible on
     that Business Day.


Regarding (1) above, for each subaccount we multiply the number of units
credited to that subaccount by its unit Value on that Business Day. The
multiplication is done before the purchase or redemption of any units on that
Business Day.

If a transaction would ordinarily require that the Contract's Fund Value be
computed for a day that is not a Business Day, the next following Business Day
will be used.


TRANSFERS. You may transfer the value of the Contract among the subaccounts
after the right to return contract period has expired by sending a proper
written request to the Company's Operations Center. Transfers may be made by
telephone, facsimile or via the web if proper authorization has been received at
the Company's Operations Center. (See "Telephone/fax/web transactions.")
Transfers will be executed at the net asset value next calculated by the Company
if the transfer instruction is received and acknowledged by 4:00 p.m., Eastern
Time on a day on which the New York Stock Exchange is open for business. If the
New York Stock Exchange is not open for business on the day of receipt, the
transfer instruction will be executed at the net asset value calculated at the
close of business on the first day thereafter on which the New York Stock
Exchange is open for business. Such transfers are subject to the Company's rules
and conditions for such privilege. Currently, there are no limitations on the
number of transfers between subaccounts. Our current transfer restrictions are
set forth in the "Disruptive transfer activity" section below.


Transfers may be postponed for any period during which

(1)  the New York Stock Exchange is closed other than customary weekend and
     holiday closings, or

(2)  trading on the New York Stock Exchange is restricted as determined by the
     Securities and Exchange Commission, or

(3)  an emergency exists as a result of which disposal of securities held by the
     Fund is not reasonably practicable or it is not reasonably practicable to
     determine the value of the net assets of the Fund.

A transfer charge is not currently imposed on transfers. (See "Deductions from
fund value -- Transfer charge.") However, the Company reserves the right to
impose a charge which will not exceed $25 per transfer. If imposed the charge
will be deducted from the first subaccount(s) or the Guaranteed Interest
Account with Market Value Adjustment you designate funds to be transferred
from. This charge is in addition to the amount transferred. All transfers in a
single request are treated as one transfer transaction. A transfer resulting
from the first reallocation of Fund Value at the end of the right to return
contract period will not be subject to a transfer charge and transfers made at
the end of an Accumulation Period of amounts allocated to the Guaranteed
Interest Account with Market Value Adjustment (see below) will not be subject
to a transfer charge. Under present law, transfers are not taxable
transactions.


TRANSFERS INVOLVING THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE
ADJUSTMENT. Transfers may be made from the Guaranteed Interest Account with
Market Value Adjustment at any time, but, if they are made before the end of the
3, 5, 7, or 10 year Accumulation Period there will be a market value adjustment
for Contracts issued in most states. If the transfer request is received within
30 days before the end of the Accumulation Period, no market value adjustment
will apply. If multiple Accumulation Periods are in effect, your transfer
request must specify from which Accumulation Period(s) we are to make the
transfer.


Contracts issued in Maryland, Massachusetts, New Jersey, Oklahoma, Oregon,
Pennsylvania, South Carolina, Texas and Washington with fund value in the
Guaranteed Interest Account with Market Value Adjustment must maintain a
minimum Fund Value in the Guaranteed Interest Account with Market Value
Adjustment of $2,500.

Please see "Payment and allocation of Purchase Payments" earlier in this
section "Detailed information about the Contract" for more information about
your role in managing your allocations.


PORTFOLIO REBALANCING. Our portfolio rebalancing program can help prevent a
well-conceived investment strategy from becoming diluted over time. Investment
performance will likely cause the allocation percentages you originally selected
to shift. With this program, you may instruct us to periodically reallocate
values in your Contract. The program does not guarantee an investment gain or
protect against an investment loss. You may elect or terminate the rebalancing
program at any time. You may also change your allocations under the program at
any time. Requesting a transfer while enrolled in our rebalancing program will
automatically terminate your participation in the program. This means that your
account will no longer be rebalanced on a periodic basis. You must provide us
with written instructions if you wish your account to be rebalanced in the
future.



TELEPHONE/FAX/WEB TRANSACTIONS

Prior allocation instructions may be changed or transfers requested by
telephone, fax or via the web subject to the Company's guidelines (which we
believe to be reasonable) and the Company's right to modify or terminate the
telephone/fax/web privilege. The Company reserves the right to deny any
telephone, fax or web request.

If all telephone lines are busy or the Internet is not available (for example,
during periods of substantial market fluctuations), Owners may be unable to
request telephone, fax or web allocation changes or transfers by telephone, fax
or web. In such cases, an Owner would submit a written request.

We have adopted guidelines relating to changes of allocations and transfers by
telephone, fax or web which, among other things, outlines procedures designed
to prevent unauthorized instructions. If the Owner does not follow these
procedures:

(1)  the Company shall not be liable for any loss as a result of following
     fraudulent telephone, fax or web instructions; and

(2)  the Owner will, therefore, bear the entire risk of loss due to fraudulent
     telephone, fax or web instructions.


23  DETAILED INFORMATION ABOUT THE CONTRACT



A copy of the guidelines and our form for electing telephone/facsimile transfer
privileges is available from your financial professional or by calling us at
(800) 487-6669, Monday through Friday, 9 a.m. to 5 p.m., Eastern Time. Web
transfer privileges and a copy of the guidelines and forms are available online
at www.axaonline.com. The telephone or fax allocation and transfer privileges
may also be elected by completing the telephone or fax authorization. The
Company's form or a Contract application with a completed telephone or fax
authorization must be signed and received at the Company's Operations Center
before telephone or fax allocation instructions will be accepted. To elect web
allocation and transfer privileges, you must log on to www.axaonline.com, and
register for online account access. This online application must be
electronically signed and received by the Company via the internet before web
transaction instructions will be accepted.


SPECIAL NOTE ON RELIABILITY. Please note that the internet or our telephone
system may not always be available. Any system, whether it is yours, your
service provider's, or your registered representative's, can experience
unscheduled outages or slowdowns for a variety of reasons. These outages or
slowdowns may delay or prevent our processing of your request. Although we have
taken precautions to help our systems handle heavy use, we cannot promise
complete reliability under all circumstances. If you are experiencing problems,
you can make your transactions by writing our Operations Center.



DISRUPTIVE TRANSFER ACTIVITY

You should note that the Contract is not designed for professional "market
timing" organizations, or other organizations or individuals engaging in a
market timing strategy. The Contract is not designed to accommodate programmed
transfers, frequent transfers or transfers that are large in relation to the
total assets of the underlying portfolio.

Frequent transfers, including market timing and other program trading or
short-term trading strategies, may be disruptive to the underlying portfolios
in which the subaccounts invest. Disruptive transfer activity may adversely
affect performance and the interests of long-term investors by requiring a
portfolio to maintain larger amounts of cash or to liquidate portfolio holdings
at a disadvantageous time or price. For example, when market timing occurs, a
portfolio may have to sell its holdings to have the cash necessary to redeem
the market timer's investment. This can happen when it is not advantageous to
sell any securities, so the portfolio's performance may be hurt. When large
dollar amounts are involved, market timing can also make it difficult to use
long-term investment strategies because a portfolio cannot predict how much
cash it will have to invest. In addition, disruptive transfers or purchases and
redemptions of portfolio investments may impede efficient portfolio management
and impose increased transaction costs, such as brokerage costs, by requiring
the portfolio manager to effect more frequent purchases and sales of portfolio
securities. Similarly, a portfolio may bear increased administrative costs as a
result of the asset level and investment volatility that accompanies patterns
of excessive or short-term trading. Portfolios that invest a significant
portion of their assets in foreign securities or the securities of small- and
mid-capitalization companies tend to be subject to the risks associated with
market timing and short-term trading strategies to a greater extent than
portfolios that do not. Securities trading in overseas markets present time
zone arbitrage opportunities when events affecting portfolio securities values
occur after the close of the overseas market but prior to the close of the U.S.
markets. Securities of small- and mid-capitalization companies present
arbitrage opportunities because the market for such securities may be less
liquid than the market for securities of larger companies, which could result
in pricing inefficiencies. Please see the prospectuses for the underlying
portfolios for more information on how portfolio shares are priced.

We currently use the procedures described below to discourage disruptive
transfer activity. You should understand, however, that these procedures are
subject to the following limitations: (1) they primarily rely on the policies
and procedures implemented by the underlying portfolios; (2) they do not
eliminate the possibility that disruptive transfer activity, including market
timing, will occur or that portfolio performance will be affected by such
activity; and (3) the design of market timing procedures involves inherently
subjective judgments, which we seek to make in a fair and reasonable manner
consistent with the interests of all policy and contract owners.

We currently require that any transfer request that would result in an
aggregated transfer amount of $250,000 or more in a single day must be
submitted in writing to our customer service office by U.S. mail (first class).
Overnight mail is not permitted for those transfer requests. We monitor the
$250,000 daily threshold on a monthly basis and combine transfer activities for
all contracts with the same or related owner. We do not permit exceptions to
this policy. We may change this policy, and any new or revised policy will
apply to all Contract holders uniformly.


We offer subaccounts with underlying portfolios that are part of the AXA
Premier VIP Trust and EQ Advisors Trust, as well as subaccounts with underlying
portfolios of outside trusts with which AXA Equitable has entered participation
agreements (the "unaffiliated trusts" and, collectively with the AXA Premier
VIP Trust and EQ Advisors Trust, the "trusts"). The trusts have adopted
policies and procedures regarding disruptive transfer activity. They discourage
frequent purchases and redemptions of portfolio shares and will not make
special arrangements to accommodate such transactions. They aggregate inflows
and outflows for each portfolio on a daily basis. On any day when a portfolio's
net inflows or outflows exceed an established monitoring threshold, the trust
obtains from us contract owner trading activity. The affiliated trusts
currently consider transfers into and out of (or vice versa) the same
subaccount within a five business day period as potentially disruptive transfer
activity.


When a Contract is identified in connection with potentially disruptive
transfer activity for the first time, a letter is sent to the Contract owner
explaining that there is a policy against disruptive transfer activity and that
if such activity continues, certain transfer privileges may be eliminated. If
and when the contract owner is identified a second time as engaged in
potentially disruptive transfer activity under the Contract, we currently
prohibit the use of voice, fax and automated transaction services. We currently
apply such action for the remaining life of each affected contract. We or a
trust may change the definition of potentially disruptive transfer activity,
the monitoring procedures and thresholds, any notification procedures, and the
procedures to restrict this activity. Any new or revised policies and
procedures will apply to all contract owners uniformly. We do not permit
exceptions to our policies restricting disruptive transfer activity.


Each unaffiliated trust may have its own policies and procedures regarding
disruptive transfer activity. If an unaffiliated trust advises us that there
may be disruptive activity from one of our contract owners, we will work with
the unaffiliated trust to review contract owner trading activity. Each trust
reserves the right to reject a transfer that it



                                     DETAILED INFORMATION ABOUT THE CONTRACT  24




believes, in its sole discretion, is disruptive (or potentially disruptive) to
the management of one of its portfolios. Please see the prospectuses for the
trusts for more information.


It is possible that a trust may impose a redemption fee designed to discourage
frequent or disruptive trading by contract owners. As of the date of this
prospectus, the trusts had not implemented such a fee. If a redemption fee is
implemented by a trust, that fee, like any other trust fee, will be borne by
the contract owner.

Contract owners should note that it is not always possible for us and the
underlying trusts to identify and prevent disruptive transfer activity. In
addition, because we do not monitor for all frequent trading at the separate
account level, contract owners may engage in frequent trading which may not be
detected, for example, due to low net inflows or outflows on the particular
day(s). Therefore, no assurance can be given that we or the trusts will
successfully impose restrictions on all potentially disruptive transfers.
Because there is no guarantee that disruptive trading will be stopped, some
contract owners may be treated differently than others, resulting in the risk
that some contract owners may be able to engage in frequent transfer activity
while others will bear the effect of that frequent transfer activity. The
potential effects of frequent transfer activity are discussed above.


TERMINATION OF THE CONTRACT

The Contract will remain in effect until the earlier of:

(1)  the date the Contract is surrendered in full,

(2)  the date annuity payments start,

(3)  the Contract Anniversary on which, after deduction for any annual contract
     charge then due, no Fund Value in the subaccounts and the Guaranteed
     Interest Account with Market Value Adjustment remains in the Contract, or

(4)  the date the death benefit is payable under the Contract.

25  DETAILED INFORMATION ABOUT THE CONTRACT



5. DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT


--------------------------------------------------------------------------------

GENERAL

The Guaranteed Interest Account with Market Value Adjustment is an allocation
option available under the contract. The Guaranteed Interest Account with
Market Value Adjustment may not be available in every state jurisdiction.

The guarantees associated with the Guaranteed Interest Account with Market
Value Adjustment are borne exclusively by the Company. The guarantees
associated with the Guaranteed Interest Account with Market Value Adjustment
are legal obligations of the Company. Fund Values allocated to the Guaranteed
Interest Account with Market Value Adjustment are held in the General Account
of the Company. Amounts allocated to the General Account of the Company are
subject to the liabilities arising from the business the Company conducts. The
Company has sole investment discretion over the investment of the assets of its
General Account. Owners having allocated amounts to a particular Accumulation
Period of the Guaranteed Interest Account with Market Value Adjustment,
however, will have no claim against any particular assets of the Company.

The Guaranteed Interest Account with Market Value Adjustment provides for a
Specified Interest Rate, which is a guaranteed interest rate that will be
credited as long as any amount allocated to the Guaranteed Interest Account
with Market Value Adjustment is not distributed for any reason prior to the
Maturity Date of the particular Accumulation Period chosen by the Owner.
Generally, a 3-year Accumulation Period offers guaranteed interest at a
Specified Interest Rate over three years, a 5-year Accumulation Period offers
guaranteed interest at a Specified Interest Rate over five years, and so on.
Because the Maturity Date is the Monthly Contract Anniversary immediately prior
to the 3, 5, 7 or 10 year anniversary of the start of the Accumulation Period,
the Accumulation Period may be up to 31 days shorter than the 3, 5, 7 or 10
years, respectively.

Although the Specified Interest Rate will continue to be credited as long as
Fund Value remains in an Accumulation Period of the Guaranteed Interest Account
with Market Value Adjustment prior to the Maturity Date of that Accumulation
Period, surrenders or transfers (including transfers to the Loan Account as a
result of a request by the Owner for a Loan) will be subject to a Market Value
Adjustment, as described below. Market Value Adjustments do not apply upon
annuitization under Settlement Option 3 or 3A.

Market Value Adjustments do not apply for partial or full surrenders or
transfers requested within 30 days before the end of the Accumulation Period,
nor to any benefits paid upon the death of the Annuitant. The Market Value
Adjustment does apply to benefits paid upon death of the Owner. Market Value
Adjustments also do not apply to Contracts issued in Maryland, Massachusetts,
New Jersey, Oklahoma, Oregon, Pennsylvania, South Carolina, Texas and
Washington. In addition, Contracts issued in these states must maintain a
minimum Fund Value balance of $2,500 in the Guaranteed Interest Account with
Market Value Adjustment when an allocation to this account is chosen.

GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT

The Guaranteed Interest Account with Market Value Adjustment is a part of the
Company's General Account which consists of all the Company's assets other than
assets allocated to segregated investment accounts of the Company, including
MONY America Variable Account A.

--------------------------------------------------------------------------------
MARKET VALUE ADJUSTMENT -- An amount added to or deducted from the amount
surrendered or transferred from the Guaranteed Interest Account with Market
Value Adjustment for contracts issued in certain states.
ACCUMULATION PERIOD -- Currently 3, 5, 7 and 10 years. The Accumulation Period
starts on the Business Day that falls on, or next follows the date the Purchase
Payment is transferred into the Guaranteed Interest Account with Market Value
Adjustment and ends on the monthly Contract anniversary immediately prior to
the last day of that Accumulation Period. (THE ACCUMULATION PERIOD IS LIMITED
TO ONE YEAR FOR CONTRACTS ISSUED IN MARYLAND, THE COMMONWEALTH OF
MASSACHUSETTS, NEW JERSEY, OKLAHOMA, OREGON, THE COMMONWEALTH OF PENNSYLVANIA,
SOUTH CAROLINA, TEXAS AND WASHINGTON.)
CONTRACT YEAR -- Any period of twelve (12) months commencing with the Effective
Date and each Contract Anniversary thereafter.
CONTRACT ANNIVERSARY -- An anniversary of the Effective Date of the Contract.
--------------------------------------------------------------------------------

ALLOCATIONS TO THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT

There are three sources from which allocations to the Guaranteed Interest
Account with Market Value Adjustment may be made:

(1)  an initial Purchase Payment made under a Contract may be wholly or
     partially allocated to the Guaranteed Interest Account with Market Value
     Adjustment;

(2)  a subsequent or additional Purchase Payment made under a Contract may be
     partially or wholly allocated to the Guaranteed Interest Account with
     Market Value Adjustment; and

(3)  amounts transferred from Subaccounts available under the Contract may be
     wholly or partially allocated to the Guaranteed Interest Account with
     Market Value Adjustment.


There is no minimum amount of any allocation of either Purchase Payments or
transfers of Fund Value to the Guaranteed Interest Account with Market Value
Adjustment. The one (1) year Accumulation Period (which is limited to certain
states in which there is no Market Value Adjustment), requires the Guaranteed
Interest Account to have a minimum Fund Value of $2,500 when an allocation to
said account is chosen.


SPECIFIED INTEREST RATES AND THE ACCUMULATION PERIODS


SPECIFIED INTEREST RATES


The Specified Interest Rate, at any given time, is the rate of interest
guaranteed by the Company to be credited to allocations made to the



 DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT  26



Accumulation Period for the Guaranteed Interest Account with Market Value
Adjustment chosen by the Owner, so long as no portion of the allocation is
distributed for any reason prior to the Maturity Date of the Accumulation
Period. Different Specified Interest Rates may be established for the four
different Accumulation Periods which are currently available (3, 5, 7 and 10
years). (The Accumulation Period is limited to one year for Contracts issued in
Maryland, the Commonwealth of Massachusetts, New Jersey, Oklahoma, Oregon, the
Commonwealth of Pennsylvania, South Carolina, Texas and Washington.)

The Company declares Specified Interest Rates for each of the available
Accumulation Periods from time to time. Normally, new Specified Interest Rates
will be declared monthly; however, depending on interest rate fluctuations,
declarations of new Specified Interest Rates may occur more or less frequently.
The Company observes no specific method in the establishment of the Specified
Interest Rates, but generally will attempt to declare Specified Interest Rates
which are related to interest rates associated with fixed-income investments
available at the time and having durations and cash flow attributes compatible
with the Accumulation Periods then available for the Guaranteed Interest
Account with Market Value Adjustment. In addition, the establishment of
Specified Interest Rates may be influenced by other factors, including
competitive considerations, administrative costs and general economic trends.
The Company has no way of predicting what Specified Interest Rates may be
declared in the future and there is no guarantee that the Specified Interest
Rate for any of the Accumulation Periods will exceed the guaranteed minimum
effective annual interest rate of 3.50%. OWNERS BEAR THE RISK THAT THE
SPECIFIED INTEREST RATE WILL NOT EXCEED THE GUARANTEED MINIMUM RATE.

The period of time during which a particular Specified Interest Rate is in
effect for new allocations to the then available Accumulation Periods is
referred to as the Investment Period. All allocations made to an Accumulation
Period during an Investment Period are credited with the Specified Interest
Rate in effect. An Investment Period ends only when a new Specified Interest
Rate relative to the Accumulation Period in question is declared. Subsequent
declarations of new Specified Interest Rates have no effect on allocations made
to Accumulation Periods during prior Investment Periods. All such prior
allocations will be credited with the Specified Interest Rate in effect when
the allocation was made for the duration of the Accumulation Period selected.

Information concerning the Specified Interest Rates in effect for the various
Accumulation Periods can be obtained by contacting an agent of the Company who
is also a registered representative of AXA Advisors, LLC or by calling the
following toll free telephone number: (800) 487-6669.

The Specified Interest Rate is credited on a daily basis to allocations made to
an Accumulation Period elected by the Owner, resulting in an annual effective
yield which is guaranteed by the Company, unless amounts are surrendered,
transferred or paid out on death of Annuitant from that Accumulation Period for
any reason prior to the Maturity Date for that Accumulation Period. The
Specified Interest Rate will be credited for the entire Accumulation Period. If
amounts are surrendered or transferred from the Accumulation Period for any
reason prior to the Maturity Date, a Market Value Adjustment will be applied to
the amount surrendered or transferred.


CREDITING OF INTEREST

Any Net Purchase Payments you as Owner of the Contract allocate to the
Guaranteed Interest Account with Market Value Adjustment will be credited with
interest at the rate declared by the Company. The Company guarantees that the
rate credited will not be less than 3.50% annually (0.0094%, compounded daily).
You bear the risk that we will not declare interest in excess of that 3.50%
rate. If you allocate Purchase Payments or transfer funds to the Guaranteed
Interest Account, you will choose between Accumulation Periods of 3, 5, 7, or
10 years for Contracts issued in most states. The Accumulation Period is
limited to one year for Contracts issued in Maryland, the Commonwealth of
Massachusetts, New Jersey, Oklahoma, Oregon, the Commonwealth of Pennsylvania,
South Carolina, Texas and Washington. Before the beginning of each calendar
month, the Company will declare interest rates for each period, if those rates
will be higher than the guaranteed rate. Each interest rate declared by the
Company will be applicable for all Net Purchase Payments received or transfers
from MONY America Variable Account A completed within the period during which
it is effective. Amounts you allocate to the Accumulation Period you select
will receive this interest rate for the entire Accumulation Period. Within 45
days, but not less than 15 days before the Accumulation Period expires, we will
notify you of the new rates we are then declaring. When the period expires you
can (1) elect a new Accumulation Period of 3, 5, 7, or 10 years (except in
certain states where the Accumulation Period is limited to a one year period)
or (2) you may elect to transfer the amounts allocated to the expiring
Accumulation Period to MONY America Variable Account A. If you make no
election, the entire amount allocated to the expiring Accumulation Period will
automatically be held for an Accumulation Period of the same length. If that
period will extend beyond the annuity starting date or if that period is no
longer offered, the money will be transferred into the Money Market subaccount.


ACCUMULATION PERIODS

For each Accumulation Period, the Specified Interest Rate in effect at the time
of the allocation to that Accumulation Period is guaranteed. An Accumulation
Period always ends on a Maturity Date, which is the Monthly Contract
Anniversary immediately prior to the 3, 5, 7 or 10 year anniversary of the
start of the Accumulation Period. Therefore, the Specified Interest Rate may be
credited for up to 31 days less than the full 3, 5, 7 or 10 years. (The
Accumulation Period is limited to one year for Contracts issued in Maryland,
the Commonwealth of Massachusetts, New Jersey, Oklahoma, Oregon, the
Commonwealth of Pennsylvania, South Carolina, Texas and Washington.)

For example, if the Effective Date of a Contract is August 10, 2000 and an
allocation is made to a 10 year Accumulation Period on August 15, 2000 and the
funds for a new Purchase Payment are received on that day, the Accumulation
Period will begin on August 15, 2000 and end on August 10, 2010, during which
period the Specified Interest Rate will be credited.

All Accumulation Periods for the 3, 5, 7, and 10 year Accumulation Periods,
respectively, will be determined in a manner consistent with the foregoing
example.


END OF ACCUMULATION PERIODS

At least fifteen days and at most forty-five days prior to the end of an
Accumulation Period, the Company will send notice to the Owner of the impending
Maturity Date. The notice will include the projected Fund Value held in the
Accumulation Period on the Maturity Date and will specify the various options
Owners may exercise with respect to the Accumulation Period:

(1)  During the thirty-day period before the Maturity Date, the Owner may wholly
     or partially surrender the Fund Value held in that



27  DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT




     Accumulation Period without a Market Value Adjustment; however, Surrender
     Charges under the Contract, if applicable, will be assessed.

(2)  During the thirty-day period before the Maturity Date, the Owner may wholly
     or partially transfer the Fund Value held in that Accumulation Period,
     without a Market Value Adjustment, to any Subaccount then available under
     the Contract or may elect that the Fund Value held in that Accumulation
     Period be held for an additional Accumulation Period of the same number of
     years or for another Accumulation Period of a different number of years
     which may at the time be available. A confirmation of any such transfer or
     election will be sent immediately after the transfer or election is
     processed.

(3)  If the Owner does not make an election within thirty days following the
     Maturity Date, the entire Fund Value held in the maturing Accumulation
     Period will be transferred to an Accumulation Period of the same number of
     years as the Accumulation Period which matured. The start of the new
     Accumulation Period is the ending date of the previous Accumulation Period.
     However, if that period would extend beyond the Annuity Starting Date of
     the Contract or if that period is not then made available by the Company,
     the Fund Value held in the maturing Accumulation Period will be
     automatically transferred to the Money Market Subaccount at the end of the
     Maturity Period. A confirmation will be sent immediately after the
     automatic transfer is executed.

During the thirty day period following the Maturity Date, and prior to any of
the transactions set forth in (1), (2), or (3) above, the Specified Value held
in the maturing Accumulation Period will continue to be credited with the
Specified Interest Rate in effect before the Maturity Date.



SURRENDERS, TRANSFERS OR LOANS


When you as Owner request that Contract Fund Value from the Guaranteed Interest
Account with Market Value Adjustment be transferred to MONY America Variable
Account A, surrendered, loaned to you, or used to pay any charge imposed in
accordance with the Contract, you should tell the Company the source by
interest rate Accumulation Period of amounts you request be transferred,
surrendered, loaned, or used to pay charges. We will not process the surrender
unless you tell us the source by interest rate Accumulation Period to use. If
you do not specify an Accumulation Period, your transaction will be processed
using the Accumulation Periods in the order in which money was most recently
allocated.


THE MARKET VALUE ADJUSTMENT


GENERAL INFORMATION REGARDING THE MVA


A surrender or transfer (including a transfer to the Loan Account as a result
of a request by the Owner for a Loan) from the Guaranteed Interest Account with
Market Value Adjustment prior to the Maturity Date of that particular
Accumulation Period, will be subject to a Market Value Adjustment. A Market
Value Adjustment will not apply upon annuitization under Settlement Option 3 or
3A, or upon payment of a death benefit. The Market Value Adjustment is
determined by the multiplication of an MVA Factor by the Specified Value, or
the portion of the Specified Value being surrendered or transferred (including
transfers for the purpose of obtaining a Loan). The Specified Value is the
amount of the allocation of Purchase Payments and transfers of Fund Value to an
Accumulation Period of the Guaranteed Interest Account with Market Value
Adjustment, plus interest accrued at the Specified Interest Rate minus prior
distributions. The Market Value Adjustment may either increase or decrease the
amount of the distribution. It will not apply to requests for transfer or full
or partial surrenders received at our administrative office within 30 days
before the end of the applicable Accumulation Period.

The Market Value Adjustment is intended to approximate, without duplicating,
the experience of the Company when it liquidates assets in order to satisfy
contractual obligations. Such obligations arise when Owners request surrenders
or transfers (including transfers for the purpose of obtaining a Loan). When
liquidating assets, the Company may realize either a gain or a loss.

A market value adjustment can increase or decrease the amounts surrendered or
transferred from the Guaranteed Interest Account with Market Value Adjustment
depending on current interest rate fluctuations.

If prevailing interest rates are higher at the time of a surrender or transfer
(including transfers for the purpose of obtaining a Loan) than the Specified
Interest Rate in effect at the time the Accumulation Period commences, the
Company will realize a loss when it liquidates assets in order to process a
surrender or transfer (including transfers for the purpose of obtaining a
Loan); therefore, application of the Market Value Adjustment under such
circumstances will decrease the amount of the surrender or transfer (including
transfers for the purpose of obtaining a Loan).

Generally, if prevailing interest rates are lower than the Specified Interest
Rate in effect at the time the Accumulation Period commences, the Company will
realize a gain when it liquidates assets in order to process a surrender or
transfer (including transfers for the purpose of obtaining a Loan); therefore,
application of the MVA under such circumstances will generally increase the
amount of the surrender or transfer (including transfers for the purpose of
obtaining a Loan) .

The Company measures the relationship between prevailing interest rates and the
Specified Interest Rates it declares through the MVA Factor. The MVA Factor is
described more fully below.



THE MVA FACTOR

The formula for determining the MVA Factor is:

                          [(1+a)/(1+b)]((n-t)/12) - 1

Where:

     a =   the Specified Interest Rate for the Accumulation Period from which
           the surrender, transfer or loan is to be taken;

     b =   the Specified Interest Rate declared at the time a surrender or
           transfer is requested for an Accumulation Period equal to the time
           remaining in the Accumulation Period from which the surrender or
           transfer (including transfer to the Loan Account as a result of a
           request by the Owner for a Loan) is requested, plus 0.25%;

     n =   the Accumulation Period from which the surrender or transfer occurs
           in months; and

     t =   the number of elapsed months (or portion thereof) in the
           Accumulation Period from which the surrender or transfer occurs.


 DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT  28




If an Accumulation Period equal to the time remaining is not issued by the
Company, the rate will be an interpolation between two available Accumulation
Periods. If two such Accumulation Periods are not available, we will use the
rate for the next available Accumulation Period.

If the Company is no longer declaring rates on new payments, we will use
Treasury yields adjusted for investment risk as the basis for the Market Value
Adjustment.

The MVA Factor shown above also accounts for some of the administrative and
processing expenses incurred when fixed-interest investments are liquidated.
This is represented in the addition of 0.25% in the MVA Factor.

The MVA Factor will be multiplied by that portion of the Specified Value being
surrendered, transferred, or distributed for any other reason. If the result is
greater than zero, a gain will be realized by the Owner; if less than zero, a
loss will be realized. If the MVA Factor is exactly zero, no gain or loss will
be realized by the Owner.



INVESTMENTS

Amounts allocated to the Guaranteed Interest Account with Market Value
Adjustment are transferred to the General Account of the Company. Amounts
allocated to the General Account of the Company are subject to the liabilities
arising from the business the Company conducts. This is unlike amounts
allocated to the Subaccounts of MONY America Variable Account A, which are not
subject to the liabilities arising from the business the Company conducts.

The Company has sole investment discretion over the investment of the assets of
the General Account. We will invest these amounts primarily in investment-grade
fixed income securities including: securities issued by the U.S. Government or
its agencies or instrumentalities, which issues may or may not be guaranteed by
the U.S. Government; debt securities that have an investment grade, at the time
of purchase, within the four highest grades assigned by Moody's Investor
Services, Inc., Standard & Poor's Corporation, or any other nationally
recognized rating service; mortgage-backed securities collateralized by real
estate mortgage loans or securities collateralized by other assets, that are
insured or guaranteed by the Federal Home Loan Mortgage Association, the
Federal National Home Mortgage Association, or the Government National Mortgage
Association, or that have an investment grade at the time of purchase within
the four highest grades described above; commercial and agricultural mortgage
loans; other debt instruments; commercial paper; cash or cash equivalents.

Variable annuity Owners having allocated amounts to a particular Accumulation
Period of the Guaranteed Interest Account with Market Value Adjustment will not
have a direct or indirect interest in these investments, nor will they have a
claim against any particular assets of the Company. The overall investment
performance of the General Account will not increase or decrease their claim
against the Company.

There is no specific formula for establishing Specified Interest Rates. The
Specified Interest Rates declared by the Company for the various Accumulation
Periods will not necessarily correspond to the performance of any group of
assets of the General Account. We will consider certain factors in determining
these rates, such as regulatory and tax environment, sales commissions,
administrative expenses borne by us, and competitive factors. The Company's
management will make the final determination of these rates. However, the
Specified Interest Rate will never be less than 3.50%.

29  DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT



6. SURRENDERS


--------------------------------------------------------------------------------

The Owner may elect to make a surrender of all or part of the Contract's Fund
Value provided it is:

o    on or before the annuity payments start, and

o    during the lifetime of the Annuitant.

Any such election shall specify the amount of the surrender. The surrender will
be effective on the date a proper written request is received by the Company at
its Operations Center.

The amount of the surrender may be equal to the Contract's Cash Value, which is
its Fund Value less:

(1)  any applicable surrender charge, and

(2)  any applicable Market Value Adjustment.

The surrender may also be for a lesser amount (a "partial surrender").
Requested partial surrenders that would leave a Cash Value of less than $1,000
are treated and processed as a full surrender. In such case, the entire Cash
Value will be paid to the Owner. For a partial surrender, any surrender charge
or any applicable Market Value Adjustment will be in addition to the amount
requested by the Owner. A partial surrender may reduce your death benefit
proportionately by the same percentage that the surrender (including any
surrender charge and any market value adjustment, if applicable) reduced Fund
Value.

A surrender will result in the cancellation of units of the particular
subaccounts and the withdrawal of amounts credited to the Guaranteed Interest
Account with Market Value Adjustment Accumulation Periods as chosen by the
Owner. The aggregate value of the surrender will be equal to the dollar amount
of the surrender plus, if applicable, any surrender charge and any applicable
Market Value Adjustment. For a partial surrender, the Company will cancel units
of the particular subaccounts and withdraw amounts from the Guaranteed Interest
Account with Market Value Adjustment Accumulation Period under the allocation
specified by the Owner. The unit value will be calculated as of the end of the
Business Day the surrender request is received. The Owner can specify partial
surrender allocations by either amount or percentage. Allocations by percentage
must be in whole percentages (totaling 100%). The minimum percentage of
allocation for a partial surrender is 10% of any subaccount or Guaranteed
Interest Account with Market Value Adjustment designated by the Owner. The
request will not be accepted if:

o    there is insufficient Fund Value in the Guaranteed Interest Account with
     Market Value Adjustment or a subaccount to provide for the requested
     allocation against it, or

o    the request is incomplete or incorrect.

Any surrender charge will be allocated against the Guaranteed Interest Account
with Market Value Adjustment and each subaccount in the same proportion that
each allocation bears to the total amount of the partial surrender. Contracts
issued in Maryland, the Commonwealth of Massachusetts, New Jersey, Oklahoma,
Oregon, the Commonwealth of Pennsylvania, South Carolina, Texas and Washington
must maintain a minimum Fund Value in the Guaranteed Interest Account with
Market Value Adjustment of $2,500.

The amount of any surrender, death benefit, or transfer payable from MONY
America Variable Account A amount will be paid in accordance with the
requirements of the 1940 Act. However, the Company may be permitted to postpone
such payment under the 1940 Act. Postponement is currently permissible only for
any period during which:

(1)  the New York Stock Exchange is closed other than customary weekend and
     holiday closings, or

(2)  trading on the New York Stock Exchange is restricted as determined by the
     Securities and Exchange Commission, or

(3)  an emergency exists as a result of which disposal of securities held by the
     Fund is not reasonably practicable or it is not reasonably practicable to
     determine the value of the net assets of the Fund.

Any surrender involving payment from amounts credited to the Guaranteed
Interest Account with Market Value Adjustment may be postponed, at the option
of the Company, for up to 6 months from the date the request for a surrender is
received by the company. Surrenders involving payment from the Guaranteed
Interest Account with Market Value Adjustment may in certain circumstances and
in certain states also be subject to a Market Value Adjustment, in addition to
a surrender charge. The Owner may elect to have the amount of a surrender
settled under one of the settlement options of the Contract. (See "Annuity
provisions".)

Contracts offered by this prospectus may be issued in connection with
retirement plans meeting the requirements of certain sections of the Internal
Revenue Code. Owners should refer to the terms of their particular retirement
plan for any limitations or restrictions on cash surrenders.

The tax results of a cash surrender should be carefully considered. (See
"Federal tax status".)

Please note: If mandated under applicable law, we may be required to reject a
Purchase Payment. In addition, we may also be required to block an Owner's
account and thereby refuse to honor any request for transfers, partial
surrenders, loans or death benefits until instructions are secured from the
appropriate regulator. We may also be required to provide additional
information about your account to government regulators.

                                                                  SURRENDERS  30



7. LOANS


--------------------------------------------------------------------------------

Qualified Contracts issued under an Internal Revenue Code Section 401(k) plan
will have a loan provision (except in the case of Contracts issued in Vermont)
under which a loan can be taken using the Contract as collateral for the loan.
All of the following conditions apply in order for the amount to be considered
a loan, rather than a (taxable) partial surrender:

o    The term of the loan must be 5 years or less.

o    Repayments are required at least quarterly and must be substantially level.

o    The loan amount is limited to certain dollar amounts as specified by the
     IRS.

The Owner (Plan Trustee) must certify that these conditions are satisfied.

In any event, the maximum outstanding loan on a Contract is 50% of the Fund
Value in the subaccounts and/or the Guaranteed Interest Account with Market
Value Adjustment. Loans are not permitted before the end of the right to return
contract period. In requesting a loan, the Owner must specify the subaccounts
from which Fund Value equal to the amount of the loan requested will be taken.
Loans from the Guaranteed Interest Account with Market Value Adjustment are not
taken until Fund Value in the subaccounts is exhausted. If in order to provide
the Owner with the amount of the loan requested, and Fund Values must be taken
from the Guaranteed Interest Account with Market Value Adjustment, then the
Owner must specify the Accumulation Periods from which Fund Values equal to
such amount will be taken. If the Owner fails to specify subaccounts and
Accumulation Periods, the request for a loan will be returned to the Owner.

Values are transferred to a loan account that earns interest at an annual rate
of 3.50%. The annual loan interest rate charged on outstanding loans will be 6%
in arrears. Any interest not paid when due will be added to the loan and bear
interest at the 6% annual rate.

Loan repayments must be specifically earmarked as loan repayment and will be
allocated to the subaccounts and/or the Guaranteed Interest Account with Market
Value Adjustment using the most recent payment allocation on record. Otherwise,
we will treat the payment as a Net Purchase Payment.

--------------------------------------------------------------------------------
LOAN -- Available under a Contract issued under Section 401(k) of the Code;
subject to availability. To be considered a Loan: (1) the term must be no more
than five years, (2) repayments must be at least quarterly and substantially
level, and (3) the amount is limited to dollar amounts specified by the Code,
not to exceed 50% of the Fund Value.
LOAN ACCOUNT -- A part of the General Account where Fund Value is held as
collateral for a loan. An Owner may transfer Fund Value in the Subaccounts,
and/or Guaranteed Interest Account with Market Value Adjustment to the Loan
Account.
--------------------------------------------------------------------------------

31  LOANS



8. DEATH BENEFIT


--------------------------------------------------------------------------------
DEATH BENEFIT PROVIDED BY THE CONTRACT

The Company will pay a death benefit to the Beneficiary if

(1)  the Annuitant dies, and

(2)  the death occurs before the annuity payments start.

If there are funds allocated to the Guaranteed Interest Account with Market
Value Adjustment at the time of death, any applicable market value adjustment
will be waived. If the death of the Annuitant occurs on or after the annuity
payments start, no death benefit will be payable except as may be provided
under the settlement option elected.


The death benefit depends upon the benefit option package in effect on the date
the Annuitant dies. You may not change benefit option packages once you select
an option. For the chart relating to the death benefit under Contracts issued
in the State of Washington, see Appendix I.





------------------------------------------------------------------------------------------------------------------------------------
 OPTION 1                                    OPTION 2                                    OPTION 3(3)
------------------------------------------------------------------------------------------------------------------------------------
 THE GREATER OF:                             THE GREATEST OF:                            THE GREATEST OF:
------------------------------------------------------------------------------------------------------------------------------------
                                                                                   
(1)  The Fund Value less any outstanding     (1)  The Fund Value less any outstanding   (1)  The Fund Value less any outstanding
     debt on the date due proof of the            debt on the date due proof of the          debt on the date due proof of the
     Annuitant's death is received by the         Annuitant's death is received by the       Annuitant's death is received by the
     Company(1)                                   Company(1)                                 Company(1)

                  or                                           or                                         or

(2)  The Purchase Payments paid, reduced     (2)  The Purchase Payments paid, reduced   (2)  The Purchase Payments paid, reduced
     proportionately by each partial              proportionately by each partial            proportionately by each partial
     surrender (reflecting any Market             surrender (reflecting any Market           surrender (reflecting any Market
     Value Adjustment and any surrender           Value Adjustment and any surrender         Value Adjustment and any surrender
     charge) and less any outstanding             charge) and less any outstanding           charge) and less any outstanding
     debt(2)                                      debt(2)                                    debt(2)

                                                               or                                         or

                                             (3)  Step Up Value (see description        (3)  Step Up Value (see description
                                                  below).                                    below)

                                                                                                          or

                                                                                        (4)  Roll Up Value (see description
                                                                                             below).
------------------------------------------------------------------------------------------------------------------------------------
                                             PLUS:                                      PLUS:
------------------------------------------------------------------------------------------------------------------------------------
                                             Earnings Increase Death Benefit (see       Earnings Increase Death Benefit (see
                                             "Earnings Increase Death Benefit"          "Earnings Increase Death Benefit" section)
                                             section)
------------------------------------------------------------------------------------------------------------------------------------




(1)  Due proof of the Annuitant's death is deemed to be received by the Company
     as of the date it receives satisfactory proof of the Annuitant's death, any
     required instructions for the method of payment, forms necessary to effect
     payment and any other information it may require.

(2)  In the calculation of the death benefit for each partial surrender, the
     proportionate reduction is equal to the amount of that partial surrender
     and any surrender charge and any market value adjustment divided by the
     Fund Value immediately before that partial surrender, multiplied by the
     Purchase Payments paid before that partial surrender. For certain Contracts
     purchased prior to July 22, 2003, the death benefit is the greater of: (1)
     The Fund Value less any outstanding debt on the date due proof of the
     Annuitant's death is received by the Company, or (2) The Purchase Payments
     paid, less any partial surrenders and their surrender charges minus any
     outstanding debt, and plus or minus any market value adjustment.

(3)  As of November 29, 2004, Option 3 was no longer available for new business.



                                                                DEATH BENEFIT 32



In general, on the death of an Owner who is not the Annuitant, amounts must be
distributed from the Contract. (See "Provisions required by Section 72(s) of
the Code" later in this prospectus.) We will impose applicable surrender
charges. (See "Charges and deductions" later in this prospectus.)



STEP UP VALUE


On the first Contract Anniversary, the Step Up Value is equal to the Fund Value
of the Contract. Thereafter, on each subsequent Contract Anniversary prior to
the Annuitant's 81st birthday, the Step Up Value will be recalculated to equal
the greater of:

(1)  the Fund Value on that Contract Anniversary; or

(2)  the Step Up Value most recently calculated


     o    reduced proportionately(1) by any partial surrenders (including
          surrender charges and any applicable market value adjustments
          assessed) since the last recalculation anniversary,


     o    plus any Purchase Payments made since the last recalculation
          anniversary.

On each Contract Anniversary on or after the annuitant's 81st birthday, the
Step Up Value shall be equal to the step up value on the Contract Anniversary
preceding the annuitant's 81st birthday reduced proportionately by the same
percentage that any partial surrenders (including surrender charges and any
applicable market value adjustments assessed) reduced your Fund Value since
that Contract Anniversary plus any Purchase Payments made since that Contract
Anniversary.

The Step Up Value payable on death will be the Step Up Value on the Contract
Anniversary immediately preceding the death of the Annuitant (or Secondary
Annuitant, if any):

o    reduced proportionately by any partial surrenders including surrender
     charges and any applicable market value adjustments assessed since that
     anniversary;

o    plus any Purchase Payments made since that Contract Anniversary; and

o    less any outstanding debt.

In no event will the Step Up Value payable on death exceed 200% of:

o    the total Purchase Payments made reduced proportionately for each partial
     surrender (including surrender charges and any applicable market value
     adjustments assessed) and

o    less any outstanding debt.


ROLL UP VALUE


The Roll Up Value will be calculated as follows. On each Contract Anniversary
prior to the Annuitant's 81st birthday, the Roll Up Value is the total of:

o    Purchase Payments accumulated at an annual interest rate of 5% from the
     date of the Purchase Payment to the date due proof of the Annuitant's death
     is received by the Company but not beyond the most recent contract
     anniversary prior to the Annuitant's 81st birthday;

o    plus any Purchase Payments made after the most recent Contract Anniversary
     prior to the Annuitant's 81st birthday but before the date due proof of
     death is received by the Company;

o    less partial surrenders (including surrender charges and any applicable
     Market Value Adjustments) accumulated at an annual interest rate of 5% from
     the date of the partial surrender to the date due proof of the Annuitant's
     death is received by the Company but not beyond the most recent Contract
     Anniversary prior to the Annuitant's 81st birthday; and

o    less any partial surrenders made after the most recent Contract Anniversary
     prior to the Annuitant's 81st birthday but before the date due proof of the
     Annuitant's death is received by the Company.

On each Contract Anniversary on or after the Annuitant's 81st birthday, the
Roll Up Value shall be equal to the Roll Up Value on the Contract Anniversary
preceding the Annuitant's 81st birthday

o    less any partial surrenders (including surrender charges and Market Value
     Adjustments assessed) since that Contract Anniversary;

o    plus any Purchase Payments made since that Contract Anniversary.

The Roll Up Value payable on death will be the Roll Up Value on the Contract
Anniversary immediately preceding the death of the Annuitant (or Secondary
Annuitant, if any)

o    less any partial surrenders (including surrender charges and any applicable
     market value adjustments assessed) since that Contract Anniversary;

o    plus any Purchase Payments made since that Contract Anniversary, and

o    less any outstanding debt.

In no event will the roll up value payable on death exceed 200% of:

o    the total Purchase Payments made reduced proportionately by the same
     percentage that any partial surrenders (including surrender charges and any
     applicable Market Value Adjustments assessed) reduced your Fund Value and;

o    less any outstanding debt.


EARNINGS INCREASE DEATH BENEFIT

If Option 2 or Option 3 was selected, an additional death benefit, called the
Earnings Increase Amount may be added to the applicable death benefit otherwise
payable under the Contract. The amount of the Earnings Increase Amount depends
upon the age of the Annuitant on the Contract's Effective Date.

If the Annuitant was age 69 or younger on the Contract's Effective Date, the
Earnings Increase Amount is equal to 40% of the lesser of:

(1)  Net Purchase Payments; or

(2)  Fund Value minus Purchase Payments.

If the Annuitant was age 70 or older on the Contract's Effective Date, the
Earnings Increase Amount is equal to 25% of the lesser of:

(1)  Net Purchase Payments; or

(2)  Fund Value minus Purchase Payments.

The payments and values described in (1) and (2) above:


----------------------
(1)  In the calculations of Step Up Value, for each partial surrender, the
     proportionate reduction percentage is equal to the amount of that partial
     surrender divided by the Fund Value immediately before the partial
     surrender.

33  DEATH BENEFIT



(a)  do not include Purchase Payments made during the 12-month period
     immediately prior to the date due proof of death is received by the
     Company; and

(b)  reflect any partial surrenders made including any applicable Market Value
     Adjustment and any surrender charge, and are reduced by any outstanding
     debt.

The Earnings Increase Amount is calculated as of the date due proof of death of
the Annuitant (or Secondary Annuitant) prior to the annuity starting date is
received by the Company.

There are important things you should consider before you select the earnings
increase death benefit. These include:

o    The earnings increase death benefit does not guarantee that any amount will
     be added to your death benefit when payable. You bear the investment risk
     of investing in the subaccounts. Market declines may cause your Fund Value
     to be less than your Net Purchase Payments. In that event, we will not pay
     any amount under the Earnings Increase Death Benefit.

o    Once you select the Earnings Increase Death Benefit, you cannot cancel it.
     This means that regardless of any changes in your circumstances, or even if
     the investment performance of the portfolios is such that the resulting
     basic death benefit would be sufficient to meet your needs, we will
     continue to assess the Earnings Increase Death Benefit charges.

o    Please take advantage of the guidance of a qualified financial adviser in
     evaluating the Earnings Increase Death Benefit option, as well as the other
     aspects of the Contract.


ELECTION AND EFFECTIVE DATE OF ELECTION

The Owner may elect to have the death benefit of the Contract applied under one
of four settlement options to effect an annuity for the Beneficiary as payee
after the death of the Annuitant. The election must take place:

(1)  during the lifetime of the Annuitant, and

(2)  before the annuity payments start.

If no election of a settlement option for the death benefit is in effect on the
date when proceeds become payable, the Beneficiary may elect:

(1)  to receive the death benefit in the form of a lump sum payment; or

(2)  to have the death benefit applied under one of the settlement options.

(See "Settlement options".) If an election by the payee is not received by the
Company within one month following the date proceeds become payable, the payee
will be considered to have elected a lump sum payment. Either election
described above may be made by filing a written election with the Company in
such form as it may require. Any proper election of a method of settlement of
the death benefit by the Owner will become effective on the date it is signed.
However, any election will be subject to any payment made or action taken by
the Company before receipt of the notice at the Company's Operations Center.

Settlement option availability may be restricted by the terms of any applicable
retirement plan and any applicable legislation for any limitations or
restrictions on the election of a method of settlement and payment of the death
benefit.

PAYMENT OF DEATH BENEFIT PROCEEDS

If the death benefit proceeds are to be paid in cash to the Beneficiary,
payment will be made within seven (7) days of the date due proof of death of
the Annuitant is received.

The Company may be permitted to postpone such payment from amounts payable from
MONY America Variable Account A under the 1940 Act. If the death benefit is to
be paid in one sum to the successor Beneficiary, or to the estate of the
deceased Annuitant, payment will be made within seven (7) days of the date due
proof of the death of the Annuitant and the Beneficiary is received by the
Company. Unless another election is made, the death benefit proceeds will be
transferred to an interest bearing checking account. The Beneficiary may make
partial or full withdrawals from such account through a checkbook provided to
the Beneficiary.

                                                               DEATH BENEFIT  34



9. CHARGES AND DEDUCTIONS



--------------------------------------------------------------------------------
The following table summarizes the charges and deductions under the Contract:



------------------------------------------------------------------------------------------------------------------------------------
                                                 DEDUCTIONS FROM PURCHASE PAYMENTS
------------------------------------------------------------------------------------------------------------------------------------
                                                          
Tax charge                                                   Range for State and local premium tax -- 0% to 3.50%(1).
                                                             Federal -- Currently 0%
                                                             (Company reserves the right to charge in the future.)
------------------------------------------------------------------------------------------------------------------------------------
                                       DAILY DEDUCTIONS FROM MONY AMERICA VARIABLE ACCOUNT A
------------------------------------------------------------------------------------------------------------------------------------
Mortality & expense risk charge                              Option 1

  Annual Rate deducted daily from average daily net assets   Maximum daily rate -- 0.003836%

Option 1 -- Current annual rate is 1.20%.                    Maximum annual rate -- 1.40%
                                                             -----------------------------------------------------------------------
                                                             Option 2
                                                             Maximum daily rate -- 0.005342%

Option 2 -- Current annual rate is 1.70%.                    Maximum annual rate -- 1.95%
                                                             -----------------------------------------------------------------------
                                                             Option 3(2)
                                                             Maximum daily rate -- 0.007671%
Option 3 -- Current annual rate is 2.35%.                    Maximum annual rate -- 2.80%
------------------------------------------------------------------------------------------------------------------------------------
                                                     DEDUCTIONS FROM FUND VALUE
------------------------------------------------------------------------------------------------------------------------------------
Annual contract charge                                       Maximum annual contract charge

Option 1 -- Current charge is $30.                           Option 1 -- The annual contract charge may be increased to a maxi-
                                                             mum of $50 on 30 days written notice.

Option 2 -- Current charge is $0.                            Option 2 -- The annual contract charge may be increased to a maxi-
                                                             mum of $50 on 30 days written notice.

Option 3(2) -- Current charge is $0.                         Option 3(2) -- The annual contract charge may be increased to a
                                                             maximum of $50 on 30 days written notice.
------------------------------------------------------------------------------------------------------------------------------------
Transaction and other charges                                Maximum Transaction and Other Charges

Transfer charge

Option 1 -- Current charge is $0.                            Option 1 -- The Company has reserved the right to impose a charge
                                                             for each transfer which will not exceed $25.

Option 2 -- Current charge is $0.                            Option 2 -- The Company has reserved the right to impose a charge
                                                             for each transfer which will not exceed $25.

Option 3(2) -- Current charge is $0.                         Option 3(2) -- The Company has reserved the right to impose a charge
                                                             for each transfer which will not exceed $25.
------------------------------------------------------------------------------------------------------------------------------------
Surrender charge

 Grades from 7% to 0% of Fund Value surrendered based on a   See grading schedule and "Charges and deductions -- Charges
 schedule                                                    against fund value" for details of how it is computed.
------------------------------------------------------------------------------------------------------------------------------------
Loan interest spread                                         2.50%
------------------------------------------------------------------------------------------------------------------------------------


(1)  Company currently assumes responsibility; current charge to Owner 0%.

(2)  As of November 29, 2004, Option 3 was no longer available for new business.

The following provides additional details of the charges and deductions under
the Contract.

Please note that the amount of the charge may not necessarily correspond to the
costs associated with providing the services or benefits indicated by the
designation of the charge. For example, the surrender charge we collect may not
fully cover all of the sales and distribution expenses we actually incur. We
also may realize a profit on one or more of the charges. We may use such
profits for any corporate purpose, including the payment of sales expenses.

35 CHARGES AND DEDUCTIONS



DEDUCTIONS FROM PURCHASE PAYMENTS


Deductions may be made from Purchase Payments for a charge for state and local
premium or similar taxes prior to allocation of any Net Purchase Payment among
the subaccounts. Currently, the Company makes no deduction, but may do so with
respect to future Purchase Payments. If the Company is going to make deductions
for such tax from future Purchase Payments, it will give notice to each
affected Owner.


CHARGES AGAINST FUND VALUE

DAILY DEDUCTION FROM MONY AMERICA VARIABLE ACCOUNT A

MORTALITY AND EXPENSE RISK CHARGE. The Company assumes mortality and expense
risks. A charge for assuming such risks is deducted daily from the net assets of
MONY America Variable Account A. The charge varies based on the benefit option
package selected.


Option 1 -- For Option 1, the daily mortality and expense risk charge from MONY
America Variable Account A is deducted at a current daily rate equivalent to an
annual rate of 1.20% from the value of the net assets of MONY America Variable
Account A. The rate is guaranteed not to exceed a daily rate equivalent to an
annual rate of 1.40% from the value of the net assets of MONY America Variable
Account A. The mortality and expense risk charge is deducted from MONY America
Variable Account A, and therefore the subaccounts, on each Business Day. Where
the previous day (or days) was not a Business Day, the deduction currently on
the next Business Day will be 0.003288% (guaranteed not to exceed 0.003836%)
multiplied by the number of days since the last Business Day.

Option 2 -- For Option 2, the daily mortality and expense risk charge from MONY
America Variable Account A is deducted at a current daily rate equivalent to an
annual rate of 1.70% from the value of the net assets of MONY America Variable
Account A. The rate is guaranteed not to exceed a daily rate equivalent to an
annual rate of 1.95% from the value of the net assets of MONY America Variable
Account A. The mortality and expense risk charge is deducted from MONY America
Variable Account A, and therefore the subaccounts, on each Business Day. Where
the previous day (or days) was not a Business Day, the deduction currently on
the next Business Day will be 0.004658% (guaranteed not to exceed 0.005342%)
multiplied by the number of days since the last Business Day.

Option 3 -- For Option 3, the daily mortality and expense risk charge from MONY
America Variable Account A is deducted at a current daily rate equivalent to an
annual rate of 2.35% from the value of the net assets of MONY America Variable
Account A. The rate is guaranteed not to exceed a daily rate equivalent to an
annual rate of 2.80% from the value of the net assets of MONY America Variable
Account A. The mortality and expense risk charge is deducted from MONY America
Variable Account A, and therefore the subaccounts, on each Business Day. Where
the previous day (or days) was not a Business Day, the deduction currently on
the next Business Day will be 0.006438% (guaranteed not to exceed 0.007671%)
multiplied by the number of days since the last Business Day.

The mortality risk assumed by the Company is that Annuitants may live for a
longer time than projected. If that occurs, an aggregate amount of annuity
benefits greater than that projected will be payable. In making this
projection, the Company has used the mortality rates from the 1983 Table "a"
(discrete functions without projections for future mortality), with 3.50%
interest. In addition, the Company also assumes risk in connection with the
Step-Up Value, Roll-Up Value and Earnings Increase Death Benefit. The expense
risk assumed is that expenses incurred in issuing and administering the
Contracts will exceed the expense charges provided in the Contracts.

Mortality and expense risk charges which may be assessed under Contracts will
not be assessed against any allocation to the Guaranteed Interest Account with
Market Value Adjustment. Such charges apply only to the Fund Value allocated to
the Subaccounts.

If the amount of the mortality and expense risk charge exceeds the amount
needed, the excess will be kept by the Company in its General Account. If the
amount of the charge is inadequate, the Company will pay the difference out of
its General Account.


DEDUCTIONS FROM FUND VALUE


ANNUAL CONTRACT CHARGE. The Company has primary responsibility for the
administration of the Contract and MONY America Variable Account A. An annual
contract charge helps to reimburse the Company for administrative expenses
related to the maintenance of the Contract. Ordinary administrative expenses
expected to be incurred include premium collection, recordkeeping, processing
death benefit claims and surrenders, preparing and mailing reports, and overhead
costs. In addition, the Company expects to incur certain additional
administrative expenses in connection with the issuance of the Contract,
including the review of applications and the establishment of Contract records.


The Company intends to administer the Contract itself through an arrangement
whereby it may buy some administrative services from AXA Equitable and such
other sources as may be available.

The current amount of the annual contract charge depends upon the benefit
option package selected.

--------------------------------------------------------------------------------
                        ANNUAL CONTRACT CHARGE
--------------------------------------------------------------------------------
      OPTION 1              OPTION 2               OPTION 3
--------------------------------------------------------------------------------
Current charge is       Current Charge is       Current Charge is $0.
$30.                    $0.
--------------------------------------------------------------------------------
The annual contract     The annual contract     The annual contract
charge may be           charge may be           charge may be
increased to a maxi-    increased to a maxi-    increased to a maxi-
mum of $50.             mum of $50.             mum of $50.
--------------------------------------------------------------------------------

The Owner will receive a written notice 30 days in advance of any change in the
charge. Any applicable charge will be assessed once per year on the Contract
Anniversary, starting on the first Contract Anniversary.

If applicable, the annual contract charge is deducted from the Fund Value on
each Contract Anniversary before the date annuity payments start.

The amount of the charge will be allocated against the Guaranteed Interest
Account with Market Value Adjustment and each subaccount of MONY America
Variable Account A in the same proportion that the Fund Value in those accounts
bears to the Fund Value of the Contract. The Company does not expect to make
any profit from the Annual Contract Charge.


TRANSFER CHARGE. Contract value may be transferred among the subaccounts or to
or from the Guaranteed Interest Account with Market Value Adjustment and one or
more of the subaccounts (including transfers made by telephone, facsimile or via
the web, if permitted by the Company). Although we currently do not charge for
transfers, the Company reserves the right to impose a transfer charge for each
trans-



                                                      CHARGES AND DEDUCTIONS  36



fer instructed by the Owner. The transfer charge compensates the Company for
the costs of effecting the transfer. The transfer charge will not exceed $25.
The Company does not expect to make a profit from the transfer charge. If
imposed, the transfer charge will be deducted from the Contract's Fund Value
held in the subaccount(s) or from the Guaranteed Interest Account with Market
Value Adjustment from which the first transfer is made.


SURRENDER CHARGE. A contingent deferred sales charge (called a "Surrender
Charge") will be imposed when a full or partial surrender is requested or at the
start of annuity benefits if it is during the first eight years of the Contract.


The surrender charge will never exceed 7% of the total Fund Value. The
surrender charge is intended to reimburse the Company for expenses incurred in
distributing the Contract. To the extent such charge is insufficient to cover
all distribution costs, the Company will make up the difference. The Company
will use funds from its General Account, which may contain funds deducted from
MONY America Variable Account A to cover mortality and expense risks borne by
the Company. (See "Mortality and expense risk charge").

We impose a surrender charge when a full or partial surrender is made during
the first eight Contract Years, except as provided below.

A surrender charge will not be imposed:

(1)  Against Fund Value surrendered after the eighth Contract Year.

(2)  To the extent necessary to permit the Owner to obtain an amount equal to
     the free partial surrender amount (See "Free partial surrender amount").

(3)  If the Contract is surrendered after the third Contract Year and the
     surrender proceeds are paid under either Settlement Option 3 or Settlement
     Option 3A (See "Settlement options"). The elimination of a surrender charge
     in this situation does not apply to Contracts issued in the State of Texas.

(4)  Subject to approval within a state, if the Owner is confined in a Nursing
     Home and the following conditions are met:

     (a)   At the time a request for a full or partial surrender is made, the
           Company receives proof the Owner is currently confined to a Nursing
           Home and has spent a period of 90 consecutive days in the Nursing
           Home;

     (b)   the confinement must have been prescribed by a physician;

     (c)   the 90-day period must have started after the Contract's first
           anniversary; and

     (d)   the Annuitant is between ages 0-75 at the time the Contract is
           issued.


--------------------------------------------------------------------------------
NURSING HOME(1) -- A facility which
(a)  is licensed by or legally operated in a state as a skilled or intermediate
     care facility;
(b)  provides 24 hour per day nursing care under the supervision of a registered
     nurse to persons who do not require hospitalization but who do require care
     above the level of room and board with assistance;
(c)  is under the supervision of a physician; and
(d)  maintains a daily clinical record of each patient in conformance with a
     plan of care.
A nursing home does not include a hospital or a facility licensed only to offer
supervised or assisted room and board, rest care, care of the aged or treatment
of alcoholism, drug addictions or mental or nervous disorders.
(1)  The definition of Nursing Home may vary by state.
--------------------------------------------------------------------------------


In no event will the aggregate surrender charge exceed 7% of the Fund Value.
Further, in no event will the surrender charges imposed, when added to any
surrender charges previously paid on the Contract, exceed 9% of aggregate
Purchase Payments made to date for the Contract.

The Owner may specify whether he/she wants the surrender charge to be deducted
from the amount requested for surrender or the Fund Value remaining. If not
specified or if the Fund Value remaining is not sufficient, then the surrender
charge will be deducted from the amount requested for surrender. If it is
specified that the surrender charge will come from the remaining Fund Value and
it is sufficient, then the Company will determine the appropriate amount to be
surrendered in order to pay the surrender charge. Any surrender charge will be
allocated against the Guaranteed Interest Account with Market Value Adjustment
and each subaccount of MONY America Variable Account A in the same proportion
that the amount of the partial surrender allocated against those accounts bears
to the total amount of the partial surrender.

If any surrender from the Guaranteed Interest Account with Market Value
Adjustment occurs prior to the Maturity Date for any particular Accumulation
Period elected by the Owner, the amount surrendered will be subject to a Market
Value Adjustment in addition to Surrender Charges.

No surrender charge will be deducted from death benefits except as described in
"Death benefit".

If an existing The MONYMaster variable annuity contract issued by MONY Life
Insurance Company of America is exchanged for this Contract, a separate
effective date will be assigned to the Contract by endorsement for purposes of
determining the amount of any Surrender Charge. The surrender charge effective
date of this Contract with the endorsement will be the effective date of the
existing The MONYMaster variable annuity contract. Your agent can provide
further details. We reserve the right to disallow exchanges at any time.


AMOUNT OF SURRENDER CHARGE. The amount of the surrender charge is equal to a
varying percentage of Fund Value during the first 8 Contract Years. The
surrender charge is determined by multiplying the surrender charge percentage
for the Contract Year by the amount of Fund Value requested as follows:


--------------------------------------------------------------------------------
                SURRENDER CHARGE PERCENTAGE TABLE
--------------------------------------------------------------------------------
 # of Contract Anniversaries Since   Surrender Charge (as a % of
           Effective Date              Fund Value surrendered)
--------------------------------------------------------------------------------
                  0                               7%
--------------------------------------------------------------------------------
                  1                               7
--------------------------------------------------------------------------------
                  2                               6
--------------------------------------------------------------------------------
                  3                               6
--------------------------------------------------------------------------------
                  4                               5
--------------------------------------------------------------------------------
                  5                               4
--------------------------------------------------------------------------------
                  6                               3
--------------------------------------------------------------------------------
                  7                               2
--------------------------------------------------------------------------------
             8 (or more)                          0
--------------------------------------------------------------------------------

The amount of the surrender charge is in addition to any applicable Market
Value Adjustment that may be made if the surrender is made from Fund Value in
the Guaranteed Interest Account with Market Value Adjustment. (See "Guaranteed
Interest Account with Market


37  CHARGES AND DEDUCTIONS



Value Adjustment -- Surrenders" and the prospectus for the Guaranteed Interest
Account with Market Value Adjustment which accompanies this prospectus for
further details.)


FREE PARTIAL SURRENDER AMOUNT.  The surrender charge may be reduced by using
the free partial surrender amount provided for in the Contract. The surrender
charge will not be deducted in the following circumstances:


(1)  For Qualified Contracts, (other than contracts issued for IRA and SEP-IRA),
     an amount each Contract Year up to the greater of:

     (a)   $10,000 (but not more than the Contract's Fund Value), or

     (b)   10% of the Contract's Fund Value at the beginning of the Contract
           Year (except if the surrender is requested during the first Contract
           Year, then 10% of the Contract's Fund Value at the time the first
           surrender is requested).

(2)  For Non-Qualified Contracts (and contracts issued for IRA and SEP-IRA), an
     amount up to 10% of the Contract's Fund Value at the beginning of the
     Contract Year (except if the surrender is requested during the first
     Contract Year, then 10% of the Contract's Fund Value at the time the first
     surrender is requested) may be received in each Contract Year without a
     surrender charge.

Free partial surrenders may only be made to the extent Cash Value in the
subaccounts and/or Guaranteed Interest Account is available. For example, the
Fund Value in the MONY America Variable Account A could decrease (due to
unfavorable investment experience) after part of the 10% was withdrawn. In that
case it is possible that there may not be enough Cash Value to provide the
remaining part of the 10% free partial surrender amount.

Contract Fund Value here means the Fund Value in the subaccounts (and the
Guaranteed Interest Account with Market Value Adjustment not the loan account).
This reduction of surrender charge does not affect any applicable Market Value
Adjustment that may be made if the surrender is made from Fund Value in the
Guaranteed Interest Account with Market Value Adjustment. (See "Guaranteed
Interest Account with Market Value Adjustment -- Surrenders" and the prospectus
for the Guaranteed Interest Account with Market Value Adjustment which
accompanies this prospectus for further details.)



TAXES


Currently, no charge will be made against MONY America Variable Account A for
federal income taxes. However, the Company may make such a charge in the future
if income or gains within MONY America Variable Account A will incur any
federal income tax liability. Charges for other taxes, if any, attributable to
MONY America Variable Account A may also be made. (See "Federal tax status".)



INVESTMENT ADVISORY AND OTHER FEES


Each portfolio in which MONY America Variable Account A invests incurs certain
fees and charges. To pay for these fees and charges, the portfolio makes
deductions from its assets. Certain portfolios available under the Contract in
turn invest in shares of other portfolios of AXA Premier VIP Trust and EQ
Advisors Trust and/or shares of unaffiliated portfolios (collectively the
"underlying portfolios"). The underlying portfolios each have their own fees
and expenses, including management fees, operating expenses, and investment
related expenses such as brokerage commissions. The portfolio expenses are
described more fully in each Fund prospectus.

We sell the Contracts through registered representatives of broker-dealers.
These registered representatives are also appointed and licensed as insurance
agents of the Company. We pay commissions to the broker-dealers for selling the
Contracts. You do not directly pay these commissions, we do. We intend to
recover commissions, marketing, administrative and other expenses and cost of
Contract benefits through the fees and charges imposed under the Contracts.
(See "Distribution of the Contracts" for more information.)

                                                      CHARGES AND DEDUCTIONS  38



10. ANNUITY PROVISIONS


--------------------------------------------------------------------------------

ANNUITY PAYMENTS

Annuity payments under a Contract will begin on the date that is selected by
the Owner when the Contract is applied for. The date chosen for the start of
annuity payments may be:

(1)  no earlier than the 10th Contract Anniversary, and

(2)  no later than the Contract Anniversary after the Annuitant's 95th birthday.

The minimum number of years from the Effective Date to the start of annuity
payments is 10. While the Annuitant is living, the date when annuity payments
start may be:

(1)  Advanced to a date that is not earlier than the 10th Contract Anniversary.

(2)  Deferred from time to time by the Owner by written notice to the Company.

The date when annuity payments start will be advanced or deferred if:

(1)  Notice of the advance or deferral is received by the Company prior to the
     current date for the start of annuity payments.

(2)  The new start date for annuity payments is a date which is not later than
     the Contract Anniversary after the Annuitant's 95th birthday.

The change will be effective as of the date we receive your written request at
our Operations Center. You do not need to return the Contract for us to make
the change unless we ask for it.

A particular retirement plan may contain other restrictions. For Contracts
issued in connection with retirement plans, reference should be made to the
terms of the particular retirement plan for any limitations or restrictions on
when annuity payments start.

When annuity payments start, unless Settlement Option 3 or 3A is elected, the
Contract's Cash Value, less any tax charge which may be imposed, will be
applied to provide an annuity or any other option previously chosen by the
owner and permitted by the Company. If Settlement Option 3 or 3A is elected,
the Contract's Fund Value (less any state taxes imposed upon annuitization)
will be applied to provide an annuity.

A supplementary contract will be issued. That contract will describe the terms
of the settlement. No payments may be requested under the Contract's surrender
provisions after annuity payments start. No surrender will be permitted except
as may be available under the settlement option elected.



GUARANTEED MINIMUM ANNUITY PAYMENTS


Under Option 3, guaranteed minimum annuity payments are available. If certain
conditions are met, a guaranteed minimum value called the "Guaranteed
Annuitization Value" may be used to provide annuity payments that are greater
than the annuity payments that would be provided by the Fund Value described in
the Contract.

The Guaranteed Annuitization Value is:

o    the sum of all Net Purchase Payments made, plus

o    interest accumulated at an annual rate of 5% (interest is credited from the
     date we receive the Purchase Payment to the Contract Anniversary prior to
     the Annuitant's 81st birthday),

o    reduced proportionately for each partial surrender including any surrender
     charges and Market Value Adjustments, if applicable.

The Guaranteed Annuitization Value provides annuity payments based on the 1983
Table "a", Projection Scale "G" with 3% interest.

In no event can the Guaranteed Annuitization Value exceed 200% of:

o    the Net Purchase Payments made reduced proportionately for each partial
     surrender, including any surrender charges and any Market Value
     Adjustments, if applicable, and

o    less any outstanding debt.

To apply the Guaranteed Annuitization Value to provide annuity payments, the
following conditions must be met:

(1)  The Contract must have been in force for at least 7 years.

(2)  The Annuitant must have attained age 60.

(3)  The annuitization must be elected within 30 days after a Contract
     anniversary.

(4)  Settlement Option 3 or 3A must be elected. (See "Settlement Options").

(5)  The entire amount of Guaranteed Annuitization Value must be used to provide
     annuity payments.

Once annuity payments provided by the Guaranteed Annuitization Value begin, no
withdrawals may be made.


The availability of guaranteed minimum annuity payments under Option 3 or 3A,
does not limit the Owner's right to start annuity payments using the Contract's
Cash Value or the Contract's Fund Value, as applicable, at any other time as
permitted under the Contract. Guaranteed minimum annuity payments are not
available under Contracts issued in the state of Washington.



ELECTION AND CHANGE OF SETTLEMENT OPTION

Instead of being paid in a single sum, you may elect to receive any death or
surrender proceeds from the Contract in the form of a settlement option. During
the lifetime of the Annuitant and prior to the start of annuity payments, the
Owner may elect:

o    one or more of the settlement options described below, or

o    another settlement option as may be agreed to by the Company.

The Owner may also change any election while the Annuitant is living if written
notice of the change is received by the Company at its Operations Center prior
to the start of annuity payments. Depending upon when you purchased your
Contract, if no election is in effect on the Annuity Starting Date, either
Settlement Option 3 with a 10-year certain or a lump sum payment will be deemed
to have been elected. For contracts issued in the State of Texas, if no
election is in effect when annuity payments start, Settlement Option 3 with a
period certain of 10 years will be considered to have been elected.


39  ANNUITY PROVISIONS



Settlement options may also be elected by the Owner or the Beneficiary as
provided in the Death benefit and Surrender sections of this prospectus. (See
"Death benefit" and "Surrenders".)

Where applicable, reference should be made to the terms of a particular
retirement plan and any applicable legislation for any limitations or
restrictions on the options that may be elected.


SETTLEMENT OPTIONS

Proceeds settled under the settlement options listed below or otherwise
currently available will not participate in the investment experience of MONY
America Variable Account A. Unless you elect Settlement Option 1, you cannot
change settlement options once settlement payments begin.


SETTLEMENT OPTION 1 -- INTEREST INCOME: The Company holds the proceeds and
credits interest earned on the proceeds at a rate (not less than 2.75% per year)
set by the Company each year. This Option will continue until the earlier of the
date the payee dies or the date you elect another settlement option. Under
certain contracts, this option is not available if the Annuitant is the payee.

SETTLEMENT OPTION 2 -- INCOME FOR SPECIFIED PERIOD: Fixed monthly payments for a
specified period of time, as elected. The payments may, at the Company's option,
be increased by additional interest each year.

SETTLEMENT OPTION 3 -- SINGLE LIFE INCOME: Payments for the life of the payee
and for a period certain. The period certain may be (a) 0 years, 10 years, or 20
years, or (b) the period required for the total income payments to equal the
proceeds (refund period certain). The amount of the income will be determined by
the Company on the date the proceeds become payable.

SETTLEMENT OPTION 3A -- JOINT LIFE INCOME: Payments during the joint lifetime of
the payee and one other person, and during the lifetime of the survivor. The
survivor's monthly income may be equal to either (a) the income payable during
the joint lifetime or (b) two-thirds of that income, depending on the election
made at the time of settlement. If the lesser (two-thirds) amount paid to the
survivor is elected, the dollar amount payable while both persons are living
will be larger than it would have been if the same amount paid to the survivor
had been elected. If a person for whom this option is chosen dies before the
first monthly payment is made, the survivor will receive proceeds instead under
Settlement Option 3, with 10 years certain.

SETTLEMENT OPTION 4 -- INCOME OF SPECIFIED AMOUNT: Income, of an amount chosen,
for as long as the proceeds and interest last. The amount chosen to be received
as income in each year may not be less than 10 percent of the proceeds settled.
Interest will be credited annually on the amount remaining unpaid at a rate
determined annually by the Company. This rate will not be less than 2.75% per
year.

The Contract contains annuity payment rates for Settlement Options 3 and 3A
described in this prospectus. The rates show, for each $1,000 applied, the
dollar amount of the monthly fixed annuity payment, when this payment is based
on minimum guaranteed interest as described in the Contract.


The annuity payment rates may vary according to the settlement option elected
and the age of the payee. The mortality table used in determining the annuity
payment rates for Settlement Options 3 and 3A is the 1983 Table "a" (discrete
functions, without projections for future mortality), with 3.50% interest per
year.

Under Settlement Option 3, if income based on the period certain elected is the
same as the income provided by another available period or periods certain, the
Company will consider the election to have been made of the longest period
certain.

In Qualified Plans, settlement options available to Owners may be restricted by
the terms of the plans.


FREQUENCY OF ANNUITY PAYMENTS

At the time the settlement option is chosen, the payee may request that it be
paid:

o    Quarterly;

o    Semiannually; or

o    Annually

If the payee does not request a particular installment payment schedule, the
payments will be made in monthly installments. However, if the net amount
available to apply under any settlement option is less than $1,000, the Company
has the right to pay such amount in one lump sum. In addition, if the payments
provided for would be less than $25, the Company shall have the right to change
the frequency of the payments to result in payments of at least $25.


ADDITIONAL PROVISIONS

The Company may require proof of the age of the Annuitant before making any
life annuity payment under the Contract. If the Annuitant's age has been
misstated, the amount payable will be the amount that would have been provided
under the settlement option at the correct age. Once life income payments
begin, any underpayments will be made up in one sum with the next annuity
payment. Overpayments will be deducted from the future annuity payments until
the total is repaid.

The Contract may be required to be returned upon any settlement. Prior to any
settlement of a death claim, proof of the Annuitant's death must be submitted
to the Company.

Where any benefits under the Contract are contingent upon the recipient's being
alive on a given date, the Company requires proof satisfactory to it that such
condition has been met.

The Contracts described in this prospectus contain annuity payment rates that
distinguish between men and women. On July 6, 1983, the Supreme Court held in
Arizona Governing Committee v. Norris that optional annuity benefits provided
under an employer's deferred compensation plan could not, under Title VII of
the Civil Rights Act of 1964, vary between men and women on the basis of sex.
Because of this decision, the annuity payment rates that apply to Contracts
purchased under an employment-related insurance or benefit program may in some
cases not vary on the basis of the Annuitant's sex. Unisex rates to be provided
by the Company will apply for Qualified Plans.

Employers and employee organizations should consider, in consultation with
legal counsel, the impact of Norris , and Title VII, generally and any
comparable state laws that may apply, on any employment-related plan for which
a Contract may be purchased.

The Contract is incontestable from its date of issue.


GUARANTEED INTEREST ACCOUNT AT ANNUITIZATION

On the Annuity Starting Date, the Contract's Cash Value, including the Cash
Value of all Accumulation Periods of the Guaranteed Interest Account with
Market Value Adjustment, will be applied to provide an


                                                          ANNUITY PROVISIONS  40



annuity or any other option previously chosen by the Owner and permitted by the
Company. No Market Value Adjustment will apply at annuitization if the owner
elects Settlement Option 3 or 3A. For more information about annuitization and
annuity options, please refer to the Contract.



41  ANNUITY PROVISIONS




11. OTHER PROVISIONS



--------------------------------------------------------------------------------

OWNERSHIP

The Owner has all rights and may receive all benefits under the Contract.
During the lifetime of the Annuitant (and Secondary Annuitant if one has been
named), the Owner is the person so designated in the application, unless:

(1)  A change in Owner is requested, or

(2)  A Successor Owner becomes the Owner.

The Owner may name a Successor Owner or a new Owner at any time. If the Owner
dies, the Successor Owner, if living, becomes the Owner. Any request for change
must be:

(1)  Made in writing, and

(2)  Received at the Company.

The change will become effective as of the date the written request is signed.
A new choice of Owner or Successor Owner will apply to any payment made or
action taken by the Company after the request for the change is received.
Owners should consult a competent tax adviser prior to changing Owners.

--------------------------------------------------------------------------------
SUCCESSOR OWNER -- The living person who, at the death of the Owner, becomes
the new Owner.
--------------------------------------------------------------------------------


PROVISION REQUIRED BY SECTION 72(S) OF THE CODE

The entire interest under a Non-Qualified Contract must be distributed within
five years after the Owner's death if:

(1)  The Owner dies before the start of annuity payments, and

(2)  The Owner's spouse is not the Successor Owner as of the date of the Owner's
     death.

Satisfactory proof of death must be provided to the Company.


Spousal status is determined under federal law for this purpose.


This provision shall not extend the term of the Contract beyond the date when
death proceeds become payable.

The surrender proceeds may be paid over the life of the Successor Owner if:

(1)  The Successor Owner is the Beneficiary, and

(2)  The Successor Owner chooses that option.

Payments must begin no later than one year after the date of death. If the
Successor Owner is a surviving spouse, then the surviving spouse will be
treated as the new Owner of the Contract. Under such circumstances, it is not
necessary to surrender the Contract.

If the Owner dies on or after annuity payments start, any remaining portion of
the proceeds will be distributed using a method that is at least as quick as
the one used as of the date of the Owner's death.


PROVISION REQUIRED BY SECTION 401(A)(9) OF THE CODE

The entire interest of a Qualified Plan participant in the Contract generally
will begin to be distributed no later than the required beginning date. For
this purpose "Qualified Plans" include those intended to qualify under Sections
401 and 408 of the Code. Distribution will occur either by or beginning not
later than April 1st of the calendar year following the calendar year the
Qualified Plan Participant attains age 70-1/2. The interest is distributed:

(1)  Over the life of such Participant, or

(2)  The lives of such Participant and designated Beneficiary.

If (i) required minimum distributions have begun, and (ii) the Participant dies
before the Owner's entire interest has been distributed to him/her, the
remaining distributions will be made using a method that is at least as rapid
as that used as of the date of the Participant's death.

The Contract generally will be surrendered as of the Participant's death if:

(1)  The Participant dies before the start of such distributions, and

(2)  There is no designated Beneficiary.

The surrender proceeds generally must be distributed within 5 years after the
date of death. But, the surrender proceeds may be paid over the life of any
designated Beneficiary at his/her option. In such case, distributions will
begin not later than one year after the December 31st following the
Participant's death. If the designated Beneficiary is the surviving spouse (as
ordered by federal law) of the Participant, distributions will begin not
earlier than the December 31st following the date on which the participant
would have attained age 70-1/2. If the surviving spouse dies before
distributions to him/her begin, the provisions of this paragraph shall be
applied as if the surviving spouse were the Participant. If the Qualified Plan
is an IRA under Section 408 of the Code, the surviving spouse may elect to
forgo distribution and treat the IRA as his/her own plan. Although the lifetime
required minimum distribution rules do not apply to Roth IRAs under Section
408A of the Code, the post-death distribution rules apply.

It is the Owner's responsibility to assure that distribution rules imposed by
the Code will be met. The Owner should consider the effect of recent revisions
to the distribution rules which could increase the minimum distribution amount
required from annuity contracts funding Qualified Plans where certain
additional benefits are purchased under the Contract. For this purpose
additional annuity contract benefits may include, but are not limited to,
guaranteed minimum income benefits and enhanced death benefits. The Owner may
want to consult a tax advisor concerning the potential application of these
complex rules before purchasing this annuity Contract, purchasing additional
features under this annuity Contract or making additional Purchase Payments
under this annuity Contract.


SECONDARY ANNUITANT

Except where the Contract is issued in connection with a Qualified Plan, a
Secondary Annuitant may be designated by the Owner. Such designation may be
made only once before annuitization, either:

(1)  In the application for the Contract, or

(2)  After the Contract is issued, by written notice to the Company at its
     Operations Center.


                                                            OTHER PROVISIONS  42



You cannot change the Secondary Annuitant, but you can delete the Secondary
Annuitant. The Secondary Annuitant may be deleted by written notice to the
Company at its Operations Center. A designation or deletion of a Secondary
Annuitant will take effect as of the date the written election was signed. The
Company, however, must first accept and record the change at its Operations
Center. The change will be subject to:

(1)  Any payment made by the Company, or

(2)  Action taken by the Company before the receipt of the notice at the
     Company's Operations Center.

The Secondary Annuitant will be deleted from the Contract automatically by the
Company as of the Contract Anniversary following the Secondary Annuitant's 95th
birthday.

On the death of the Annuitant, the Secondary Annuitant will become the
Annuitant, under the following conditions:

(1)  The death of the Annuitant must have occurred before the Annuity Starting
     Date;

(2)  The Secondary Annuitant is living on the date of the Annuitant's death;

(3)  If the Annuitant was the Owner on the date of death, the Successor Owner
     must have been the Annuitant's spouse (as defined by federal law); and

(4)  If the date annuity payments start is later than the Contract Anniversary
     nearest the Secondary Annuitant's 95th birthday, the date annuity payments
     start will be automatically advanced to that Contract Anniversary.


EFFECT OF SECONDARY ANNUITANT'S BECOMING THE ANNUITANT. If the Secondary
Annuitant becomes the Annuitant, the Death Benefit proceeds will be paid to the
Beneficiary only on the death of the Secondary Annuitant. If the Secondary
Annuitant was the Beneficiary on the Annuitant's death, the Beneficiary will be
automatically changed to the person who was the successor Beneficiary on the
date of death. If there was no successor Beneficiary, then the Secondary
Annuitant's executors or administrators, unless the Owner directed otherwise,
will become the Beneficiary. All other rights and benefits under the Contract
will continue in effect during the lifetime of the Secondary Annuitant as if the
Secondary Annuitant were the Annuitant.



ASSIGNMENT

The Owner may assign the Contract. However, the Company will not be bound by
any assignment until the assignment (or a copy) is received by the Company at
its Operations Center. The Company is not responsible for determining the
validity or effect of any assignment. The Company shall not be liable for any
payment or other settlement made by the Company before receipt of the
assignment.

If the Contract is issued under certain retirement plans, then it may not be
assigned, pledged or otherwise transferred except under conditions allowed
under applicable law.

Because an assignment may be a taxable event, an Owner should consult a
competent tax advisor before assigning the Contract.


CHANGE OF BENEFICIARY

So long as the Annuitant is living, the Owner may change the Beneficiary or
successor Beneficiary. A change is made by submitting a written request to the
Company at its Operations Center. The form of the request must be acceptable to
the Company. The Contract need not be returned unless requested by the Company.
The change will take effect as of the date the request is signed. The Company
will not, however, be liable for any payment made or action taken before
receipt of the request at its Operations Center.


SUBSTITUTION OF SECURITIES

The Company may substitute shares of another mutual fund for shares of the
Funds already purchased or to be purchased in the future by Contract Purchase
Payments if:

(1)  The shares of any portfolio of the Funds is no longer available for
     investment by MONY America Variable Account A, or

(2)  In the judgment of the Company's Board of Directors, further investment in
     shares of one or more of the portfolios of the Funds is inappropriate based
     on the purposes of the Contract.

The new portfolios may have higher fees and charges than the ones they
replaced, and not all portfolios may be available to all classes of contracts.
We will notify you before we substitute securities in any subaccount, and, to
the extent required by law, we will obtain prior approval from the Securities
and Exchange Commission and the Arizona Insurance Department. We also will
obtain any other required approvals. (See "Who is MONY Life Insurance Company
of America -- MONY America Variable Account A" for more information about
changes we may make to the subaccounts).


CHANGES TO CONTRACTS

The Company reserves the right, subject to compliance with laws that apply, to
unilaterally change your Contract in order to comply with any applicable laws
and regulations, including but not limited to changes in the Internal Revenue
Code, in Treasury regulations or in published rulings of the Internal Revenue
Service, ERISA and in Department of Labor regulations.

Any change in the Contract must be in writing and made by our authorized
officer. We will provide notice of any contract change.


CHANGE IN OPERATION OF MONY AMERICA VARIABLE ACCOUNT A

To the extent permitted by applicable law, MONY America Variable Account A (i)
may be operated as a management company under the 1940 Act,(ii) may be
deregistered under the 1940 Act in the event the registration is no longer
required, or (iii) may be combined with any of our other MONY America separate
accounts.

Deregistration of MONY America Variable Account A requires an order by the
Securities and Exchange Commission. If there is a change in the operation of
MONY America Variable Account A under this provision, the Company may make
appropriate endorsement to the Contract to reflect the change and take such
other action as may be necessary and appropriate to effect the change.

43  OTHER PROVISIONS



12. VOTING RIGHTS


--------------------------------------------------------------------------------

All of the assets held in the subaccounts of MONY America Variable Account A
will be invested in shares of the designated portfolios of the Funds. The
Company is the legal holder of these shares.

To the extent required by law, the Company will vote the shares of each of the
Funds held in MONY America Variable Account A (whether or not attributable to
Owners).

We will determine the number of votes which you have the right to cast by
applying your percentage interest in a subaccount to the total number of votes
attributable to that subaccount. In determining the number of votes, we will
recognize fractional shares.

We will vote portfolio shares of a class held in a subaccount for which we
received no timely instructions in proportion to the voting instructions which
we received for all contracts participating in that subaccount. We will apply
voting instructions to abstain on any item to be voted on a pro-rata basis to
reduce the number of votes eligible to be cast.

Whenever a Fund calls a shareholders meeting, each person having a voting
interest in a subaccount will receive proxy voting material, reports, and other
materials relating to the relevant portfolio. Since each Fund may engage in
shared funding, other persons or entities besides the Company may vote Fund
shares.

                                                               VOTING RIGHTS  44



13. DISTRIBUTION OF THE CONTRACTS


--------------------------------------------------------------------------------


The contracts are distributed by both AXA Advisors, LLC ("AXA Advisors") and
AXA Distributors, LLC ("AXA Distributors") (together, the "Distributors"). The
Distributors serve as principal underwriters of MONY America Variable Account
A. The offering of the Contracts is intended to be continuous.

AXA Advisors is an affiliate of the Company, and AXA Distributors is an
indirect wholly owned subsidiary of the Company. The Distributors are under the
common control of AXA Financial, Inc. Their principal business address is 1290
Avenue of the Americas, New York, NY 10104. The Distributors are registered
with the SEC as broker-dealers and are members of the Financial Industry
Regulatory Authority, Inc. ("FINRA" ). Both broker-dealers also act as
distributors for the Company's life and annuity products.

The Contracts are sold by financial professionals of AXA Advisors and its
affiliates. The Contracts are also sold by financial professionals of
unaffiliated broker-dealers that have entered into selling agreements with the
Distributors ("Selling broker-dealers").

The Company pays compensation to both Distributors based on contracts sold. The
Company may also make additional payments to the Distributors, and the
Distributors may, in turn, make additional payments to certain Selling
broker-dealers. All payments will be in compliance with all applicable FINRA
rules and other laws and regulations.

Although the Company takes into account all of its distribution and other costs
in establishing the level of fees and charges under its Contracts, none of the
compensation paid to the Distributors or the Selling broker-dealers discussed
in this section of the prospectus are imposed as separate fees or charges under
your Contract. The Company, however, intends to recoup amounts it pays for
distribution and other services through the fees and charges of the Contract
and payments it receives for providing administrative, distribution and other
services to the Portfolios. For information about the fees and charges under
the Contract, see "Summary of the Contract" and "Charges and deductions"
earlier in this prospectus.

COMPENSATION PAID TO THE DISTRIBUTORS The Company pays compensation to the
Distributors based on Purchase Payments made on the Contracts sold through the
Distributors ("contribution-based compensation"). The contribution-based
compensation will generally not exceed 6.50% of total Purchase Payments made
under the Contracts, plus, starting in the second Contract Year, up to 0.25% of
the cash value of the Contracts ("asset-based compensation"). The Distributors,
in turn, may pay a portion of the compensation received from the Company to the
Distributors financial professional and/or the Selling broker-dealer making the
sale. The compensation paid by the Distributors varies among financial
professionals and among Selling broker-dealers. The Distributors also pay a
portion of the compensation it receives to its managerial personnel. When a
Contract is sold by a Selling broker-dealer, the Selling broker-dealer, not the
Distributors, determines the amount and type of compensation paid to the Selling
broker-dealer's financial professional for the sale of the Contract. Therefore,
you should contact your financial professional for information about the
compensation he or she receives and any related incentives, as described below.

AXA Advisors also pays its financial professionals and managerial personnel
other types of compensation including service fees, expense allowance payments
and health and retirement benefits. AXA Advisors also pays its financial
professionals, managerial personnel and Selling broker-dealers sales bonuses
(based on selling certain products during specified periods) and persistency
bonuses. AXA Advisors may offer sales incentive programs to financial
professionals and Selling broker-dealers who meet specified production levels
for the sales of both the Company's Contracts and Contracts offered by other
companies. These incentives provide non-cash compensation such as stock options
awards and/or stock appreciation rights, expense-paid trips, expense-paid
education seminars and merchandise.

The Company also pays AXA Distributors compensation to cover its operating
expenses and marketing services under the terms of the Company's distribution
agreements with AXA Distributors.

DIFFERENTIAL COMPENSATION PAID BY AXA ADVISORS. In an effort to promote the sale
of the Company's products, AXA Advisors may pay its financial professionals and
managerial personnel a greater percentage of contribution-based compensation
and/or asset-based compensation for the sale of the Company's contract than it
pays for the sale of a Contract or other financial product issued by a company
other than the Company. This practice is known as providing "differential
compensation." Differential compensation may involve other forms of compensation
to AXA Advisors personnel. Certain components of the compensation paid to
managerial personnel are based on whether the sales involve the Company's
Contracts. Managers earn higher compensation (and credits toward awards and
bonuses) if the financial professionals they manage sell a higher percentage of
the Company's Contracts than products issued by other companies. Other forms of
compensation provided to its financial professionals include health and
retirement benefits, expense reimbursements, marketing allowances and
contribution-based payments, known as "overrides." For tax reasons, AXA Advisors
financial professionals qualify for health and retirement benefits based solely
on their sales of the Company's Contracts and products sponsored by affiliates.

The fact that AXA Advisors financial professionals receive differential
compensation and additional payments may provide an incentive for those
financial professionals to recommend the Company's Contract over a Contract or
other financial product issued by a company not affiliated with the Company.
However, under applicable rules of FINRA, AXA Advisors financial professionals
may only recommend to you products that they reasonably believe are suitable
for you based on the facts that you have disclosed as to your other security
holdings, financial situation and needs. In making any recommendation,
financial professionals of AXA Advisors may nonetheless face conflicts of
interest because of the differences in compensation from one product category
to another, and because of differences in compensation among products in the
same category. For more information, contact your financial professional.

ADDITIONAL PAYMENTS BY AXA DISTRIBUTORS TO SELLING BROKER-DEALERS.  AXA
Distributors may pay, out of its assets, certain Selling broker-dealers and
other financial intermediaries additional compensation in recognition of
services provided or expenses incurred. AXA Distributors may



45  DISTRIBUTION OF THE CONTRACTS




also pay certain Selling broker-dealers or other financial intermediaries
additional compensation for enhanced marketing opportunities and other services
(commonly referred to as "marketing allowances"). Services for which such
payments are made may include, but are not limited to, the preferred placement
of the Company's products on a company and/or product list; sales personnel
training; product training; business reporting; technological support; due
diligence and related costs; advertising, marketing and related services;
conference; and/or other support services, including some that may benefit the
contract owner. Payments may be based on the aggregate account value
attributable to contracts sold through a Selling broker-dealer or such payments
may be a fixed amount. AXA Distributors may also make fixed payments to Selling
broker-dealers, for example in connection with the initiation of a new
relationship or the introduction of a new product.

Additionally, as an incentive for the financial professionals of Selling
broker-dealers to promote the sale of the Company's products, AXA Distributors
may increase the sales compensation paid to the Selling broker-dealer for a
period of time (commonly referred to as "compensation enhancements").

These additional payments may serve as an incentive for Selling broker-dealers
to promote the sale of the Company contracts over contracts and other products
issued by other companies. Not all Selling broker-dealers receive additional
payments, and the payments vary among Selling broker-dealers. The list below
includes the names of Selling broker-dealers that we are aware (as of December
31, 2010) received additional payments. These additional payments ranged from
$127 to $3,689,426. The Company and its affiliates may also have additional
business arrangements with Selling broker-dealers. For more information, ask
your financial professional.

1st Global Capital Corporation
Advantage Capital Corporation
AG Edwards
American General Securities Inc
American Portfolios Financial Services
Ameriprise Financial Services, Inc.
Associated Securities Corp.
Bank of America
BBVA Compass Investment Solutions, Inc.
CCO Investment Services Corp.
Centaurus Financial, Inc.
Colonial Brokerage, Inc.
Comerica Securities
Commonwealth Financial Network
CUSO Financial Services, LP
Essex National Securities Inc
FFP
Financial Network Investment Corporation
First Allied Securities
First Citizens Investor Services
First Tennessee Brokerage, Inc.
FSC Securities Corporation
Geneos Wealth Management, Inc.
H.D. Vest Investment Securities, Inc.
Investment Centers of America/First Dakota Inc.
IFC Holdings Inc. DBA Invest Financial Corporation
Investment Professionals, Inc.
Investors Capital Corporation
Ironstone Securities, Inc
J.P. Turner & Co. LLC
James T. Borello & Co.
Janney Montgomery Scott
Key Investment Services, LLC
Lincoln Financial Advisors Corporation
Lincoln Financial Securities Corporation
LPL Financial Corporation
M&T Securities
Merrill Lynch Life Agency
MML Investors Services LLC
Morgan Keegan
Morgan Stanley Smith Barney - Morgan Stanley & Co., Incorporated
Multi-Financial Securities Corporation
National Planning Corporation
Next Financial Group, Inc.
NFP Securities, Inc.
Pension Planners Securities Inc
PNC Investments
Prime Capital Services
PrimeVest Financial Services, Inc.
Oppenheimer & Co. Inc.
Raymond James & Associates Inc
Raymond James Financial Service
RBC Capital Markets Corp.
Robert W Baird
Royal Alliance Associates Inc.
RW Baird - Robert N. Baird & Co. Incorporated
Sage Point Financial, Inc
Securities America, Inc.
SII Investments, Inc.
Sorrento Pacific Financial LLC
Stifel, Nicolaus & Co.
Summit Brokerage Services, Inc
Termed/Gunnallen Financial, Inc.
Termed/Mutual Service Corporation
Transamerica Financial Advisors, Inc.
U.S Bancorp Investments, Inc.
UBS Financial Services, Inc.
United Planners' Financial Service of America
UVEST Financial Services Group, Inc.
Waterstone Financial Group, Inc.
Wells Fargo Advisors Financial Network LLC
Wells Fargo Advisors
Wells Fargo Advisors, LLC
Wells Fargo Investments, LLC
Woodbury Financial Services, Inc.


                                               DISTRIBUTION OF THE CONTRACTS  46




14. FEDERAL TAX STATUS



--------------------------------------------------------------------------------

INTRODUCTION

The Contract described in this prospectus is designed for use in connection
with Qualified Plans and on a nonqualified basis. The ultimate effect of
federal income taxes on:

o    the value of the Contract's Fund Value,

o    annuity payments,

o    death benefit, and

o    economic benefit to the Owner, Annuitant, and the Beneficiary may depend
     upon

o    the type of retirement plan for which the Contract is purchased, and

o    the tax and employment status of the individual concerned.


The following discussion of the treatment of the Contract and of the Company
under the federal income tax laws is general in nature. The discussion is based
on the Company's understanding of current federal income tax laws, and is not
intended as tax advice. These federal income tax laws may change without
notice. We cannot predict whether, when, or how these rules could change. Any
change could affect contracts purchased before the change. Congress may also
consider proposals in the future to comprehensively reform or overhaul the
United States tax and retirement systems, which if enacted, could affect the
tax benefits of a contract. We cannot predict what, if any, legislation will
actually be proposed or enacted. Any person considering the purchase of a
contract or making additional Purchase Payments under the Contract should
consult a qualified tax adviser. Additional information on the treatment of the
Contract under federal income tax laws is contained in the Statement of
Additional Information. THE COMPANY DOES NOT MAKE ANY GUARANTEE REGARDING ANY
TAX STATUS, FEDERAL, STATE, OR LOCAL, OF ANY CONTRACT OR ANY TRANSACTION
INVOLVING THE CONTRACT.



TAXATION OF ANNUITIES IN GENERAL

The Contract described in this prospectus is designed for use in connection
with Qualified Plans and on a nonqualified basis. All or a portion of the
contributions to such plans will be used to make Purchase Payments under the
Contract. In general, contributions to Qualified Plans and income earned on
contributions to all plans are tax-deferred until distributed to plan
participants or their beneficiaries. Such tax deferral is not, however,
available for Non-Qualified Contracts if the Owner is other than a natural
person unless the contract is held as an agent for a natural person. Annuity
payments made under a contract are generally taxable to the Annuitant as
ordinary income except to the extent of:

o    participant after-tax contributions (in the case of Qualified Plans), or

o    owner contributions (in the case of Non-Qualified Contracts).

Owners, Annuitants, and Beneficiaries should seek advice from their own tax
advisers about the tax consequences of distributions, withdrawals and payments
under Non-Qualified Contracts and under any Qualified Plan in connection with
which the Contract is purchased. For Qualified Contracts, among other things
individuals should discuss with their tax advisers are the "required minimum
distribution rules" which generally require distributions to be made after age
70-1/2 and after death, including requirements applicable to the calculation of
such required distributions from annuity contracts funding Qualified Plans.

Federal tax law imposes requirements for determining the amount includable in
gross income with respect to distributions not received as an annuity.
Distributions include, but are not limited to, transfers, including gratuitous
transfers, and pledges of the contract both of which are treated the same as
distributions. Distributions from all annuity contracts issued during any
calendar year by the same company (or an affiliate) to the Owner (other than
those issued to qualified retirement plans) in the same year will be treated as
distributed from one annuity contract. The IRS is given power to prescribe
additional rules to prevent avoidance of this rule through serial purchases of
contracts or otherwise. None of these rules affects Qualified Plans.

The Company will withhold and remit to the United States Government and, where
applicable, to state and local governments, part of the taxable portion of each
distribution made under a contract unless the Owner or Annuitant:

(1)  Provides his or her taxpayer identification number to the Company, and

(2)  Notifies the Company that he or she chooses not to have amounts withheld.

Distributions of plan benefits from qualified retirement plans, other than
traditional individual retirement arrangements ("traditional IRAs"), generally
will be subject to mandatory federal income tax withholding unless they are:

(1)  Part of a series of substantially equal periodic payments (at least
     annually) for:

     (a)   the participant's life or life expectancy,

     (b)   the joint lives or life expectancies of the participant and his/
           her beneficiary,

     (c)   or a period certain of not less than 10 years;

(2)  Required minimum distributions; or

(3)  Qualifying hardship distributions.

The withholding can be avoided if the participant's interest is directly rolled
over by the old plan to another eligible traditional retirement plan, including
an IRA. A direct rollover to the new plan can be made only in accordance with
the terms of the old plan.

The Company may be liable for payment of the generation skipping transfer tax
under certain circumstances. In the event that the Company determines that such
liability exists, an amount necessary to pay the generation skipping transfer
tax may be subtracted from the death benefit proceeds.

RETIREMENT PLANS

Aside from Contracts purchased on a non-qualified basis, the Contract described
in this prospectus currently is designed for use with the following types of
retirement plans:


47  FEDERAL TAX STATUS



(1)  Pension and Profit Sharing Plans established by business employers and
     certain associations, as permitted by Sections 401(a) and 401(k) of the
     Code, including those purchasers who would have been covered under the
     rules governing H.R. 10 (Keogh) Plans;

(2)  Individual Retirement Annuities permitted by Section 408(b) of the Code,
     including Simplified Employee Pensions established by employers pursuant to
     Section 408(k);

(3)  Roth IRAs permitted by Section 408A of the Code; and

(4)  Deferred compensation plans provided by certain governmental entities and
     tax-exempt organizations under Section 457.

The tax rules applicable to participants in such retirement plans vary
according to the type of plan and its terms and conditions. Therefore, no
attempt is made here to provide more than general information about the use of
the Contract with the various types of retirement plans. Participants in such
plans as well as Owners, Annuitants, and Beneficiaries are cautioned that the
rights of any person to any benefits under these plans are subject to the terms
and conditions of the plans themselves, regardless of the terms and conditions
of the Contract. The Company will provide purchasers of Contracts used in
connection with Individual Retirement Annuities with such supplementary
information as may be required by the Internal Revenue Service or other
appropriate agency. Any person contemplating the purchase of a Contract should
consult a qualified tax adviser.


TAX TREATMENT OF THE COMPANY

Under existing federal income tax laws, the income of MONY America Variable
Account A, to the extent that it is applied to increase reserves under the
Contract, is substantially nontaxable to the Company.

                                                          FEDERAL TAX STATUS  48



15. ADDITIONAL INFORMATION AND INCORPORATION OF CERTAIN INFORMATION BY
REFERENCE


--------------------------------------------------------------------------------


The Company's Annual Report on Form 10-K for the period ended December 31, 2010
(the "Annual Report") is considered to be part of this prospectus because it is
incorporated by reference.

The Company files reports and other information with the SEC, as required by
law. You may read and copy this information at the SEC's public reference
facilities at Room 1580, 100 F Street, NE, Washington, DC 20549, or by
accessing the SEC's website at www.sec.gov. The public may obtain information
on the operation of the Public Reference Room by calling the SEC at
1-800-SEC-0330. Under the Securities Act of 1933, The Company has filed with
the SEC a registration statement relating to the Guaranteed Interest Account
with Market Value Adjustment (the "Registration Statement"). This prospectus
has been filed as part of the Registration Statement and does not contain all
of the information set forth in the Registration Statement.


After the date of this prospectus and before we terminate the offering of the
securities under the Registration Statement, all documents or reports we file
with the SEC under the Securities Exchange Act of 1934 ("Exchange Act"), will
be considered to become part of this prospectus because they are incorporated
by reference.

Any statement contained in a document that is or becomes part of this
prospectus, will be considered changed or replaced for purposes of this
prospectus if a statement contained in this prospectus changes or is replaced.
Any statement that is considered to be a part of this prospectus because of its
incorporation will be considered changed or replaced for the purpose of this
prospectus if a statement contained in any other subsequently filed document
that is considered to be part of this prospectus changes or replaces that
statement. After that, only the statement that is changed or replaced will be
considered to be part of this prospectus.

We file the Registration Statement and our Exchange Act documents and reports,
including our Annual Report on Form 10-K and Quarterly Reports on Form 10-Q,
electronically according to EDGAR under CIK No. 0000835357. The SEC maintains a
website that contains reports, proxy and information statements, and other
information regarding registrants that file electronically with the SEC. The
address of the site is www.sec.gov.

Upon written or oral request, we will provide, free of charge, to each person
to whom this prospectus is delivered, a copy of any or all of the documents
considered to be part of this prospectus because they are incorporated herein.
In accordance with SEC rules, we will provide copies of any exhibits
specifically incorporated by reference into the text of the Exchange Act
reports (but not any other exhibits). Requests for documents should be directed
to MONY Life Insurance Company of America, 1290 Avenue of the Americas, New
York, New York 10104. Attention: Corporate Secretary (telephone: (212)
554-1234). You can access our website at www.axa-equitable.com.

49  ADDITIONAL INFORMATION AND INCORPORATION OF CERTAIN INFORMATION BY
REFERENCE



16. LEGAL PROCEEDINGS


--------------------------------------------------------------------------------

MONY Life Insurance Company of America and its affiliates are parties to
various legal proceedings. In our view, none of these proceedings would be
considered material with respect to an Owner's interest in MONY America
Variable Account A, nor would any of these proceedings be likely to have a
material adverse effect upon MONY America Variable Account A, our ability to
meet our obligations under the contracts, or the distribution of the contracts.


                                                           LEGAL PROCEEDINGS  50



17. FINANCIAL STATEMENTS


--------------------------------------------------------------------------------


The audited financial statements of MONY America Variable Account A and the
Company are set forth in the Statement of Additional Information. These
financial statements have been audited by PricewaterhouseCoopers LLP, an
independent registered public accounting firm.

The financial statements of the Company should be considered only as bearing
upon the ability of the Company to meet its obligations under the Contracts.
You should not consider the financial statements of the Company as affecting
investment performance of assets in the Variable Account.
PricewaterhouseCoopers LLP also provides independent audit services and certain
other non-audit services to the Company as permitted by the applicable SEC
independence rules, and as disclosed in the Company's Form 10-K.
PricewaterhouseCoopers LLP's address is 300 Madison Avenue, New York, New York
10017.


ABOUT THE GENERAL ACCOUNT

This Contract was offered to customers through various financial institutions,
brokerage firms and their affiliate insurance agencies. No financial
institution, brokerage firm or insurance agency has any liability with respect
to a Contract's account value or any guaranteed benefits with which the
Contract was issued. The Company is solely responsible to the Contract owner
for the Contract's account value and such guaranteed benefits. The general
obligations and any guaranteed benefits under the Contract are supported by the
Company's general account and are subject to the Company's claims paying
ability. An owner should look to the financial strength of the Company for its
claims-paying ability. Assets in the general account are not segregated for the
exclusive benefit of any particular Contract or obligation. General account
assets are also available to the insurer's general creditors and the conduct of
its routine business activities, such as the payment of salaries, rent and
other ordinary business expenses. For more information about the Company's
financial strength, you may review its financial statements and/or check its
current rating with one or more of the independent sources that rate insurance
companies for their financial strength and stability. Such ratings are subject
to change and have no bearing on the performance of the variable investment
options. You may also speak with your financial representative.

The general account is subject to regulation and supervision by the Insurance
Department of the State of Arizona and to the insurance laws and regulations of
all jurisdictions where we are authorized to do business. Interests under the
contracts in the general account have not been registered and are not required
to be registered under the Securities Act of 1933 because of exemptions and
exclusionary provisions that apply. The general account is not required to
register as an investment company under the Investment Company Act of 1940 and
it is not registered as an investment company under the Investment Company Act
of 1940. The contract is a "covered security" under the federal securities
laws.

We have been advised that the staff of the SEC has not reviewed the portions of
this prospectus that relate to the general account. The disclosure with regard
to the general account, however, may be subject to certain provisions of the
federal securities laws relating to the accuracy and completeness of statements
made in prospectuses.



51  FINANCIAL STATEMENTS



Appendix I: Benefit option packages, table of fees, examples and charges and
deductions for contracts issued in the State of Washington


--------------------------------------------------------------------------------

                            SUMMARY OF THE CONTRACT


BENEFIT OPTION PACKAGES

There are two benefit option packages under the Contract. Each benefit option
package is distinct. You select a benefit option package at the time of
application. Once a selection is made, you may not transfer from one benefit
option package to another.




------------------------------------------------------------------------------------------------------------------------------------
                                     OPTION 1                                   OPTION 2
------------------------------------------------------------------------------------------------------------------------------------
                                  
MORTALITY AND                        Current annual rate--1.20%                 Current annual rate--1.70%
EXPENSE RISK CHARGE                  Maximum annual rate--1.40%                 Maximum annual rate--1.95%
------------------------------------------------------------------------------------------------------------------------------------
DEATH BENEFIT ON DEATH OF ANNUITANT  THE GREATER OF:                            THE GREATEST OF:
                                     (1)  The Fund Value less any               (1)  The Fund Value less any
                                          outstanding debt on the date               outstanding debt on the date
                                          due proof of the Annuitant's               due proof of the Annuitant's
                                          death is received by the                   death is received by the
                                          Company.                                   Company.

                                                      or                                         or

                                     (2)  The Purchase Payments paid,           (2)  The Purchase Payments paid,
                                          reduced proportionately by                 reduced proportionately by
                                          each partial surrender                     each partial surrender
                                          (reflecting any Market Value               (reflecting any Market Value
                                          Adjustment and any surrender               Adjustment and any surrender
                                          charge) and less any                       charge) and less any
                                          outstanding debt.(1)                       outstanding debt.(1)

                                                                                                 or

                                                                                (3)  Step Up Value (See "Death
                                                                                     benefit")
------------------------------------------------------------------------------------------------------------------------------------
MINIMUM INITIAL PURCHASE PAYMENT     Qualified Contracts--The minimum           Qualified Contracts--The minimum
                                     Purchase Payment for qualified             Purchase Payment for qualified
                                     plans is the same for both                 plans is the same for both
                                     options. (See "Detailed                    options. (See "Detailed
                                     information about the contract.")          information about the contract.")
                                     Non-Qualified Contracts--$5,000            Non-Qualified Contracts--$10,000
------------------------------------------------------------------------------------------------------------------------------------
ANNUITANT ISSUE AGE                  Qualified Contracts--0-80                  Qualified Contracts--0-79
                                     Non-Qualified Contracts--0-80              Non-Qualified Contracts--0-79
------------------------------------------------------------------------------------------------------------------------------------
ANNUAL CONTRACT CHARGE               Current charge is $30.                     Current charge is $0.
                                                                                The annual contract charge may be
                                                                                increased to a maximum of $30 on
                                                                                30 days written notice.
------------------------------------------------------------------------------------------------------------------------------------




(1)  In the calculation of the death benefit, for each partial surrender, the
     proportionate reduction is equal to the amount of that partial surrender
     and any surrender charge and any Market Value Adjustment divided by the
     Fund Value immediately before that partial surrender, multiplied by the
     Purchase Payments paid before that partial surrender.


     For certain Contracts purchased prior to July 22, 2003 , the death benefit
     is greater of: (1) the Fund Value less any outstanding debt on the date due
     proof of the Annuitant's death is received by the Company, or (2) the
     Purchase Payments paid, less any partial surrenders and their surrender
     charges, less any outstanding debt and plus or minus any Market Value
     Adjustment.


    APPENDIX I: BENEFIT OPTION PACKAGES, TABLE OF FEES, EXAMPLES AND CHARGES AND
                                                                  DEDUCTIONS I-1



FEE TABLES

The following tables describe the fees and expenses that you will pay when
buying, owning, and surrendering the Contract.

The first table describes the fees and expenses that you will pay at the time
that you buy the Contract, surrender the Contract, or transfer fund value
between investment options. State premium taxes may also be deducted.



-----------------------------------------------------------------------------------------------------------------
 OWNER TRANSACTION EXPENSES:
-----------------------------------------------------------------------------------------------------------------
                                                                       
Maximum deferred sales load (surrender charge)                             7.00%(1)
(as a percentage of Purchase Payments surrendered)
-----------------------------------------------------------------------------------------------------------------
Loan interest spread (effective annual rate)                               2.50%(2)
-----------------------------------------------------------------------------------------------------------------
Maximum transfer charge                                                    $25(3)
-----------------------------------------------------------------------------------------------------------------

-----------------------------------------------------------------------------------------------------------------



The next table describes the fees and expense that you will pay periodically
during the time that you own the Contract, not including Fund portfolio company
fees and expenses.



-----------------------------------------------------------------------------------------------------------------
 MAXIMUM ANNUAL CONTRACT CHARGE                                                                 $30(4)
-----------------------------------------------------------------------------------------------------------------
 SEPARATE ACCOUNT ANNUAL EXPENSES:
 (AS A PERCENTAGE OF AVERAGE ANNUAL FUND VALUE IN THE VARIABLE ACCOUNT):
-----------------------------------------------------------------------------------------------------------------
                                                                                          
OPTION 1
-----------------------------------------------------------------------------------------------------------------
Maximum mortality and expense risk fees                                    1.40%(5)
-----------------------------------------------------------------------------------------------------------------
Total separate account annual expenses                                     1.40%(5)
-----------------------------------------------------------------------------------------------------------------
OPTION 2
-----------------------------------------------------------------------------------------------------------------
Maximum mortality and expense risk fees                                    1.95%(6)
-----------------------------------------------------------------------------------------------------------------
Total separate account annual expenses                                     1.95%(6)
-----------------------------------------------------------------------------------------------------------------


(1)  The surrender charge percentage, which reduces to zero, is determined under
     a surrender charge schedule. (See "Deductions from fund value -- Amount of
     surrender charge.")

     The surrender charge may be reduced under certain circumstances which
     include reduction in order to guarantee that certain amounts may be
     received free of the surrender charge. (See "Deductions from fund value --
     Free partial surrender amount.")

(2)  The loan interest spread is the difference between the amount of interest
     we charge on loans and the amount of interest we credit to amounts held in
     the loan account to secure loans.

(3)  The transfer charge currently is $0. However, the Company has reserved the
     right to impose a charge for each transfer after the first 12 transfers in
     a Contract Year, which will not exceed $25. (See "Deductions from fund
     value -- Transfer charge.")

(4)  The annual contract charge for Option 1 is currently $30. The annual
     contract charge for Option 2 is currently $0. However, the Company may in
     the future change the amount of the charge to an amount not exceeding $30
     per Contract Year. (See "Deductions from fund value -- Annual contract
     charge.")

(5)  The mortality and expense risk charge is deducted daily equivalent to a
     current annual rate of 1.20% (and is guaranteed not to exceed a daily rate
     equivalent to an annual rate of 1.40%) from the value of the net assets of
     MONY America Variable Account A.

(6)  The mortality and expense risk charge is deducted daily equivalent to a
     current annual rate of 1.70% (and is guaranteed not to exceed a daily rate
     equivalent to an annual rate of 1.95%) from the value of the net assets of
     MONY America Variable Account A.


The next item shows the minimum and maximum total operating expenses charged by
the portfolio companies for the year ended December 31, 2010. You may pay
portfolio company operating expenses periodically during the time that you own
the Contract. More detail concerning each Fund portfolio company's fees and
expenses is contained in the prospectus for each portfolio.





-----------------------------------------------------------------------------------------------------------------
 TOTAL ANNUAL FUND PORTFOLIO
 OPERATING EXPENSES:                                                      LOWEST     HIGHEST

-----------------------------------------------------------------------------------------------------------------
                                                                               
Expenses that are deducted from portfolio company assets, including        0.37%      1.78%
management fees, distribution and/or services fees (12b-1 fees), and
other expenses
-----------------------------------------------------------------------------------------------------------------




I-2 APPENDIX I: BENEFIT OPTION PACKAGES, TABLE OF FEES, EXAMPLES AND CHARGES
AND DEDUCTIONS



EXAMPLE


This example is intended to help you compare the cost of investing in the
Contract with the cost of investing in other variable annuity contracts. These
costs include contract owner transaction expenses, contract fees, separate
account annual expense, and Fund fees and expenses for the year ended December
31, 2010.


The example assumes that you invest $10,000 in the Contract for the time
periods indicated. The example also assumes that your investment has a 5%
return each year. The example assumes the minimum and maximum fees and expenses
of any of the Fund portfolios. Although your actual costs may be higher or
lower, based on these assumptions, your costs would be:


1.  a.  If you surrender your Contract at the end of the applicable time period
        (assuming maximum fees and expenses of any of the Fund portfolios):


        ------------------------------------------------------------------------
                           1 YEAR       3 YEARS      5 YEARS    10 YEARS
        ------------------------------------------------------------------------
            Option 1       $  990       $1,634       $2,293      $3,756

            Option 2       $1,041       $1,783       $2,537      $4,231
        ------------------------------------------------------------------------

    b.  If you surrender your Contract at the end of the applicable time period
        (assuming minimum fees and expenses of any of the Fund portfolios):


        ------------------------------------------------------------------------
                           1 YEAR       3 YEARS      5 YEARS    10 YEARS
        ------------------------------------------------------------------------
            Option 1       $858         $1,239       $1,635      $2,400

            Option 2       $910         $1,395       $1,898      $2,954
        ------------------------------------------------------------------------


2.  a.  If you do not surrender your Contract (assuming maximum fees and
        expenses of any of the Fund portfolios):

        ------------------------------------------------------------------------
                           1 YEAR       3 YEARS      5 YEARS    10 YEARS
        ------------------------------------------------------------------------
            Option 1       $351         $1,068       $1,807      $3,756

            Option 2       $405         $1,227       $2,064      $4,231
        ------------------------------------------------------------------------

    b.  If you do not surrender your Contract (assuming minimum fees and
        expenses of any of the Fund portfolios):



        ------------------------------------------------------------------------
                           1 YEAR       3 YEARS      5 YEARS    10 YEARS
        ------------------------------------------------------------------------
            Option 1       $210         $649         $1,114      $2,400

            Option 2       $265         $814         $1,390      $2,954
        ------------------------------------------------------------------------


3.  a.  If you annuitize your Contract and the proceeds are settled under
        Settlement Options 3 or 3A (life income with annuity options) (assuming
        maximum fees and expenses of any of the Fund portfolios):


        ------------------------------------------------------------------------
                           1 YEAR       3 YEARS      5 YEARS    10 YEARS
        ------------------------------------------------------------------------
            Option 1       $  990       $1,068       $1,807      $3,756

            Option 2       $1,041       $1,227       $2,064      $4,231
        ------------------------------------------------------------------------

    b.  If you annuitize your Contract and the proceeds are settled under
        Settlement Options 3 or 3A (life income with annuity options) (assuming
        minimum fees and expenses of any of the Fund portfolios):


        ------------------------------------------------------------------------
                           1 YEAR       3 YEARS      5 YEARS    10 YEARS
        ------------------------------------------------------------------------
            Option 1       $858         $649         $1,114      $2,400

            Option 2       $910         $814         $1,390      $2,954
        ------------------------------------------------------------------------

4.  a.  If you annuitize your Contract and the proceeds are settled under
        Settlement Options 1, 2 or 4 (annuity income without life contingencies)
        (assuming maximum fees and expenses of any of the Fund portfolios):


        ------------------------------------------------------------------------
                           1 YEAR       3 YEARS      5 YEARS    10 YEARS
        ------------------------------------------------------------------------
            Option 1       $  990       $1,634       $2,293      $3,756

            Option 2       $1,041       $1,783       $2,537      $4,231
        ------------------------------------------------------------------------

    b.  If you annuitize your Contract and the proceeds are settled under
        Settlement Options 1, 2 or 4 (annuity income without life contingencies)
        (assuming minimum fees and expenses of any of the Fund portfolios):


        ------------------------------------------------------------------------
                           1 YEAR       3 YEARS      5 YEARS    10 YEARS
        ------------------------------------------------------------------------
            Option 1       $858         $1,239       $1,635      $2,400

            Option 2       $910         $1,395       $1,898      $2,954
        ------------------------------------------------------------------------

For the purposes of the Fee Tables and the Example, we assume that the Contract
is owned during the accumulation period. (See "Charges and Deductions.") On and
after the annuity starting date, different fees and charges will apply.



                APPENDIX I: BENEFIT OPTION PACKAGES, TABLE OF FEES, EXAMPLES AND
                                                      CHARGES AND DEDUCTIONS I-3




                    DETAILED INFORMATION ABOUT THE CONTRACT


PAYMENT AND ALLOCATION OF PURCHASE PAYMENTS


Issue ages

The issue ages for the two benefit option packages available under the Contract
vary as per the table below. The maximum issue age of the Annuitant for Option
1 is 85. The maximum issue age of the Annuitant for Option 2 is 79.



------------------------------------------------------------------------------------------------------------------------------------
                                                OPTION 1                                OPTION 2
------------------------------------------------------------------------------------------------------------------------------------
                                                                                  
       Annuitant Issue Ages                     0-85                                      0-79
------------------------------------------------------------------------------------------------------------------------------------



                                 DEATH BENEFIT


DEATH BENEFIT PROVIDED BY THE CONTRACT


The death benefit depends upon the benefit option package in effect on the date
the Annuitant dies. You may not change benefit option packages once you select
an option.




------------------------------------------------------------------------------------------------------------------------------------
 OPTION 1                                                                OPTION 2
------------------------------------------------------------------------------------------------------------------------------------
 THE GREATER OF:                                                         THE GREATEST OF:
------------------------------------------------------------------------------------------------------------------------------------
                                                                      

(1)  The Fund Value less any outstanding debt on the date                (1)  The Fund Value less any outstanding debt on the date
     due proof of the Annuitant's death is received by the                    due proof of the Annuitant's death is received by the
     Company.                                                                 Company.

                            or                                                                       or

(2)  The Purchase Payments paid, reduced proportionately by              (2)  The Purchase Payments paid, reduced proportionately by
     each partial surrender and their surrender charges, any                  each partial surrender and their surrender charges,
     outstanding debt and plus or minus any Market Value                      less any outstanding debt and plus or minus any Market
     Adjustment.(1)                                                           Value Adjustment.(1)

                                                                                                     or

                                                                         (3)  Step Up Value (See "Step Up Value" in the prospectus)
------------------------------------------------------------------------------------------------------------------------------------




(1)  In the calculations of the death benefit, for each partial surrender, the
     proportionate reduction is equal to the amount of that partial surrender
     and any surrender charge and any Market Value Adjustment divided by the
     Fund Value immediately before that partial surrender, multiplied by the
     Purchase Payments paid before that partial surrender. For certain Contracts
     purchased prior to July 22, 2003, the death benefit is the greater of: (1)
     the Fund Value less any outstanding debt on the date due proof of the
     Annuitant's death is received by the Company, or (2) the Purchase Payments
     paid, less any partial surrenders and their surrender charges, less any
     outstanding debt and plus or minus any Market Value Adjustment.



I-4 APPENDIX I: BENEFIT OPTION PACKAGES, TABLE OF FEES, EXAMPLES AND CHARGES
AND DEDUCTIONS



                             CHARGES AND DEDUCTIONS

The following table summarizes the charges and deductions under the Contract:



                                                                  
------------------------------------------------------------------------------------------------------------------------------------
                                                 DEDUCTIONS FROM PURCHASE PAYMENTS
------------------------------------------------------------------------------------------------------------------------------------
Tax charge                                                           Range for State and local premium tax -- 0% to 3.50%(1).
                                                                     Federal -- currently 0%
                                                                     (Company reserves the right to charge in the future.)
------------------------------------------------------------------------------------------------------------------------------------
                                       DAILY DEDUCTIONS FROM MONY AMERICA VARIABLE ACCOUNT A
------------------------------------------------------------------------------------------------------------------------------------
Separate account annual expenses:

Mortality & expense risk charge                                      Option 1
Annual rate deducted daily from net assets                           Maximum daily rate -- 0.003836%
                                                                     Maximum annual rate -- 1.40%
                                                                     Option 2
                                                                     Maximum daily rate -- 0.005342%
                                                                     Maximum annual rate -- 1.95%
------------------------------------------------------------------------------------------------------------------------------------
                                                     DEDUCTIONS FROM FUND VALUE
------------------------------------------------------------------------------------------------------------------------------------
Annual contract charge                                               Maximum annual contract charge

Option 1 -- Current charge is $30.                                   Option 1 -- The maximum annual contract charge is $30.

Option 2 -- Current charge is $0.                                    Option 2 -- The annual contract charge may be increased to
                                                                     a maximum of $30 on 30 days written notice.
------------------------------------------------------------------------------------------------------------------------------------
Transaction and other charges                                        Maximum transaction and other charges

Transfer charge                                                      Option 1 -- The Company has reserved the right to impose a
                                                                     charge for each transfer after the first 12 transfers in a
Option 1 -- Current charge is $0.                                    Contract Year which will not exceed $25.

Option 2 -- Current charge is $0.                                    Option 2 -- The Company has reserved the right to impose a
                                                                     charge for each transfer after the first 12 transfers in a
                                                                     Contract Year which will not exceed $25.
------------------------------------------------------------------------------------------------------------------------------------
Surrender charge                                                     See grading schedule and "Charges and deductions --
                                                                     Charges against fund value" for details of how it is computed.
Grades from 7% to 0% of Fund Value surrendered based on a schedule
------------------------------------------------------------------------------------------------------------------------------------
Loan interest spread                                                 2.50%
------------------------------------------------------------------------------------------------------------------------------------


(1)  Company currently assumes responsibility; current charge to Owner 0%.

Please note that the amount of the charge may not necessarily correspond to the
costs associated with providing the services or benefits indicated by the
designation of the charge. For example, the surrender charge we collect may not
fully cover all of the sales and distribution expenses we actually incur. We
also may realize a profit on one or more of the charges. We may use such
profits for any corporate purpose, including the payment of sales expenses.

DEDUCTIONS FROM PURCHASE PAYMENTS

Deductions may be made from Purchase Payments for state and local premium taxes
prior to allocation of any Net Purchase Payment among the subaccounts.
Currently, the Company makes no deduction, but may do so with respect to future
payments. If the Company is going to make deductions for such tax from future
Purchase Payments, it will give notice to each affected Owner.

CHARGES AGAINST FUND VALUE

Daily deduction from MONY America Variable Account A

Mortality and expense risk charge. The Company assumes mortality and expense
risks. A charge for assuming such risks is deducted daily from the net assets
of MONY America Variable Account A. The charge varies based on the benefit
option package selected. The mortality and expense risk charge will not be
deducted from the Guaranteed Interest Account.

Option 1 -- For Option 1, the daily mortality and expense risk charge from MONY
America Variable Account A is deducted at a current daily rate equivalent to an
annual rate of 1.20% from the value of the net assets of MONY America Variable
Account A. The rate is guaranteed not to exceed a daily rate equivalent to an
annual rate of 1.40% from the value of the net assets of MONY America Variable
Account A. The mortality and expense risk charge is deducted from MONY America
Variable Account A, and therefore the subaccounts, on each Business Day. Where
the previous day (or days) was not a Business Day, the deduction currently on
the next Business Day will be 0.003288% (guaranteed not to exceed 0.003836%)
multiplied by the number of days since the last Business Day.

Option 2 -- For Option 2, the daily mortality and expense risk charge from MONY
America Variable Account A is deducted at a current daily rate equivalent to an
annual rate of 1.70% from the value of the net assets of MONY America Variable
Account A. The rate is guaranteed not to exceed a daily rate equivalent to an
annual rate of 1.95% from the value of the net assets of MONY America Variable
Account A. The mortality and expense


                    APPENDIX I: BENEFIT OPTION PACKAGES, TABLE OF FEES, EXAMPLES
                                                  AND CHARGES AND DEDUCTIONS I-5



risk charge is deducted from MONY America Variable Account A, and therefore the
subaccounts, on each Business Day. Where the previous day (or days) was not a
Business Day, the deduction currently on the next Business Day will be
0.004658% (guaranteed not to exceed 0.005342%) multiplied by the number of days
since the last Business Day.

The mortality risk assumed by the Company is that Annuitants may live for a
longer time than projected. If that occurs, an aggregate amount of annuity
benefits greater than that projected will be payable. In making this
projection, the Company has used the mortality rates from the 1983 Table "a"
(discrete functions without projections for future mortality), with 3.50%
interest. In addition, the Company also assumes risk in connection with the
Step-Up Value. The expense risk assumed is that expenses incurred in issuing
and administering the Contracts will exceed the expense charges provided in the
Contracts.

If the amount of the charge exceeds the amount needed, the excess will be kept
by the Company in its General Account. If the amount of the charge is
inadequate, the Company will pay the difference out of its General Account.

DEDUCTIONS FROM FUND VALUE

Annual contract charge. The Company has primary responsibility for the
administration of the Contract and MONY America Variable Account A. An annual
contract charge helps to reimburse the Company for administrative expenses
related to the maintenance of the Contract. Ordinary administrative expenses
expected to be incurred include premium collection, recordkeeping, processing
death benefit claims and surrenders, preparing and mailing reports, and
overhead costs. In addition, the Company expects to incur certain additional
administrative expenses in connection with the issuance of the Contract,
including the review of applications and the establishment of Contract records.


The Company intends to administer the Contract itself.

The current amount of the annual contract charge depends upon the benefit
option package selected.



------------------------------------------------------------------------------------------------------------------------------------
 ANNUAL CONTRACT CHARGE
------------------------------------------------------------------------------------------------------------------------------------
 OPTION 1                                                    OPTION 2
------------------------------------------------------------------------------------------------------------------------------------
                                                          
Current charge is $30.                                       Current charge is $0.
------------------------------------------------------------------------------------------------------------------------------------
The maximum annual contract charge is $30.                   The annual contract charge may be increased to a maximum of $30.
------------------------------------------------------------------------------------------------------------------------------------


The Owner will receive a written notice 30 days in advance of any change in the
charge. Any applicable charge will be assessed once per year on the contract
anniversary, starting on the first contract anniversary.

If applicable, the annual contract charge is deducted from the Fund Value on
each Contract Anniversary before the date annuity payments start.

The amount of the charge will be allocated against the Guaranteed Interest
Account and each subaccount of MONY America Variable Account A in the same
proportion that the Fund Value in those accounts bears to the Fund Value of the
Contract. The Company does not expect to make any profit from the annual
contract charge.

I-6 APPENDIX I: BENEFIT OPTION PACKAGES, TABLE OF FEES, EXAMPLES AND CHARGES
AND DEDUCTIONS



Appendix II: Condensed financial information



--------------------------------------------------------------------------------

                     MONY LIFE INSURANCE COMPANY OF AMERICA
                             MONY AMERICA VARIABLE
                                   ACCOUNT A
                            ACCUMULATION UNIT VALUES




-----------------------------------------------------------------------------------------------------
                                                           UNIT VALUE
                                    -----------------------------------------------------------------
                                            DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 1                                     2010       2009       2008       2007
-----------------------------------------------------------------------------------------------------
                                                                 
All Asset Allocation                        $  11.37   $  10.01   $  8.03    $  11.67
-----------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                       8.46       7.57      6.02       10.02
-----------------------------------------------------------------------------------------------------
AXA Conservative Allocation                    10.47       9.87      9.10       10.35
-----------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation                9.91       9.20      8.13       10.22
-----------------------------------------------------------------------------------------------------
AXA Moderate Allocation                         9.57       8.81      7.62       10.21
-----------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                    9.08       8.24      6.83       10.14
-----------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap                 12.13       9.19      6.84       12.47
 Growth
-----------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity                10.92       9.84      7.65       12.20
-----------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income               13.00      11.37     10.32       15.43
-----------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible                 9.33       8.39      6.49       11.99
-----------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                   13.54      11.80      9.07       15.17
-----------------------------------------------------------------------------------------------------
EQ/Core Bond Index                             13.29      12.68     12.47       13.82
-----------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions              13.65      12.61     10.94       12.85
-----------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                   24.54      18.73     13.40       19.56
-----------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity                  25.63      23.22     15.64       37.02
-----------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond                12.11      11.73        --          --
 Index
-----------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                         8.86       7.95      6.67       11.84
-----------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income               12.41      10.67      9.12       14.51
-----------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                               14.32      11.50      8.52       16.96
-----------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                          13.60      11.24        --          --
-----------------------------------------------------------------------------------------------------
EQ/Money Market                                10.72      10.84     10.94       10.81
-----------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                    11.41      10.67      8.33       12.56
-----------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth               11.61       8.86      5.70       10.91
-----------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                      12.50      12.55     11.76       12.40
-----------------------------------------------------------------------------------------------------
EQ/Small Company Index                         17.93      14.38     11.51       17.65
-----------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                       11.16       9.99      7.63       12.88
-----------------------------------------------------------------------------------------------------
Franklin Income Securities Fund                16.89      15.17     11.32       16.29
-----------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities           14.90      12.50     10.78       14.96
-----------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund            5.70       5.23      4.15       10.36
-----------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care                12.38      11.90      9.43       13.37
-----------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity Portfo-       11.13      10.16      8.86       14.98
 lio
-----------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                   10.03       8.37      5.38        9.82
-----------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio             15.85      15.07     10.45       18.98
-----------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio          28.42      23.00     13.00       27.54
-----------------------------------------------------------------------------------------------------



-----------------------------------------------------------------------------------------------------
                                                                UNIT VALUE
                                     ----------------------------------------------------------------
                                            DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 1                                     2006       2005       2004       2003       2002
-----------------------------------------------------------------------------------------------------
                                                                         
All Asset Allocation                        $  11.30   $  10.38   $  9.99    $  9.31   $ 7.80
-----------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                         --         --        --         --      --
-----------------------------------------------------------------------------------------------------
AXA Conservative Allocation                       --         --        --         --      --
-----------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation                  --         --        --         --      --
-----------------------------------------------------------------------------------------------------
AXA Moderate Allocation                           --         --        --         --      --
-----------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                      --         --        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap                    --         --        --         --      --
 Growth
-----------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity                12.20      10.21        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income               15.06      13.14     12.52      10.75    8.59
-----------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible                10.82      10.40        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                      --         --        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/Core Bond Index                             13.54         --        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions              12.57      11.35     10.98      10.55      --
-----------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                   18.11      15.43     14.96      12.52    9.22
-----------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity                  26.32         --        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond                   --         --        --         --      --
 Index
-----------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                           --         --        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income               14.16         --        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                               15.85         --        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                             --         --        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/Money Market                                10.42      10.07        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                    10.52       9.87      9.47       9.21    7.96
-----------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth                  --         --        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                      11.26      11.35     11.40      11.01   10.55
-----------------------------------------------------------------------------------------------------
EQ/Small Company Index                            --         --        --         --      --
-----------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                       12.89      11.43     10.62       9.49    7.53
-----------------------------------------------------------------------------------------------------
Franklin Income Securities Fund                15.89      13.60     13.55      12.04      --
-----------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities           15.56      13.45     13.16      12.00      --
-----------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund           13.48      11.72     11.20      10.43    8.14
-----------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care                12.10      11.64     10.89      10.25    8.11
-----------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity Portfo-       14.22      11.87     11.36      10.12    7.94
 lio
-----------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                    9.22       8.45      8.37       7.91    5.96
-----------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio             14.06      13.04     11.73      10.06    8.47
-----------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio          21.78      15.03     11.53       9.83    7.40
-----------------------------------------------------------------------------------------------------



                               APPENDIX II: CONDENSED FINANCIAL INFORMATION II-1







-----------------------------------------------------------------------------------------------------
                                                           UNIT VALUE
                                    -----------------------------------------------------------------
                                            DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 1                                     2010       2009       2008       2007
-----------------------------------------------------------------------------------------------------
                                                                   
MFS(R) Utilities Series                       26.08      23.19      17.62      28.61
-----------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond                12.73      12.05      11.10      14.64
-----------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                 12.38       9.81       7.38      12.91
-----------------------------------------------------------------------------------------------------
Oppenheimer Global Securities                 20.62      18.04      13.10      22.22
 Fund/VA
-----------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)              18.96      17.18      14.88      15.19
-----------------------------------------------------------------------------------------------------
ProFund VP Bear                                5.06       6.23       8.74       6.32
-----------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity            5.79       6.98       5.34       8.71
-----------------------------------------------------------------------------------------------------
ProFund VP UltraBull                           9.84       8.15       5.70      17.71
-----------------------------------------------------------------------------------------------------



-----------------------------------------------------------------------------------------------------
                                                                UNIT VALUE
                                     ----------------------------------------------------------------
                                            DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 1                                     2006       2005       2004       2003       2002
-----------------------------------------------------------------------------------------------------
                                                                          
MFS(R) Utilities Series                      22.64      17.46      15.12      11.75       8.75
-----------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond               14.33        --         --         --         --
-----------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                12.60      11.57      10.88       9.79       8.05
-----------------------------------------------------------------------------------------------------
Oppenheimer Global Securities                21.20      18.28      16.22      13.81        --
 Fund/VA
-----------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)             14.01      13.55      14.68      13.44      11.88
-----------------------------------------------------------------------------------------------------
ProFund VP Bear                               6.36       6.96       7.14       8.06        --
-----------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity           9.30       8.55       9.39      10.67        --
-----------------------------------------------------------------------------------------------------
ProFund VP UltraBull                         17.77      14.62      14.42      12.45        --
-----------------------------------------------------------------------------------------------------




II-2 APPENDIX II: CONDENSED FINANCIAL INFORMATION









------------------------------------------------------------------------------------------------------------
                                                             UNITS OUTSTANDING
                                     -----------------------------------------------------------------------
 Option 1                                    Dec. 31,      Dec. 31,     Dec. 31,     Dec. 31,
                                               2010          2009         2008         2007
------------------------------------------------------------------------------------------------------------
                                                                      
All Asset Allocation                         284,988        402,599      454,450      497,633
------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                     69,560         87,195       34,683       43,742
------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                  139,523        117,841       93,700       22,315
------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation             106,443        125,852       98,447       37,693
------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                      456,870        535,669      401,832      132,668
------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                 195,148        288,764      210,275       40,787
------------------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap Growth         59,499         92,448      115,398      129,235
------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity              259,823        304,903      286,323      342,400
------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income             237,862        273,942      358,388      407,611
------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible               31,532         34,661       43,411       36,001
------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                  77,287         90,905      134,883      149,809
------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                           839,224      1,005,876      954,215    1,292,354
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions             54,897         65,571       93,427      103,885
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                 462,321        559,452      712,525      888,336
------------------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity                105,697        138,077      167,674      208,439
------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond Index        493,557        631,723           --           --
------------------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                       93,177         95,155      127,233      178,467
------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income             456,935        587,034      712,776    1,013,981
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                             320,926        398,495      501,289      566,547
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                        521,623        651,958           --           --
------------------------------------------------------------------------------------------------------------
EQ/Money Market                              700,462      1,132,470    1,246,668    1,182,243
------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                  623,515        746,208      872,072    1,081,298
------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth             423,351        486,679      554,686      709,131
------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                    338,445        587,834      529,836      324,629
------------------------------------------------------------------------------------------------------------
EQ/Small Company Index                       105,145        120,840      150,816      175,510
------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                     179,349        202,769      192,608      241,384
------------------------------------------------------------------------------------------------------------
Franklin Income Securities Fund              521,989        668,906      869,677    1,054,022
------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities          85,918         86,265      127,156      182,045
------------------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund          39,878         47,906       61,638       74,773
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care               57,293         70,804       92,691      114,062
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity Portfolio    90,575        105,553      126,925      224,820
------------------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                  64,418         53,831       58,382       73,449
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio           217,365        281,114      305,780      374,145
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio        334,711        404,463      480,782      630,845
------------------------------------------------------------------------------------------------------------
MFS(R) Utilities Series                      118,120        149,734      187,254      220,173
------------------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond               309,259        339,607      357,943      468,645
------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                227,899        264,362      316,585      395,880
------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities Fund/VA        184,931        240,294      355,444      417,130
------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)             254,379        355,733      436,029      447,782
------------------------------------------------------------------------------------------------------------
ProFund VP Bear                                6,581          8,250       14,925        6,368
------------------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity          519,994        523,403      550,106      588,907
------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                          45,060         47,419       59,202       63,189
------------------------------------------------------------------------------------------------------------



------------------------------------------------------------------------------------------------------------
                                                                   UNITS OUTSTANDING
                                     -----------------------------------------------------------------------
 Option 1                                     Dec. 31,     Dec. 31,     Dec. 31,     Dec. 31,    Dec. 31,
                                                2006         2005         2004         2003        2002
------------------------------------------------------------------------------------------------------------
                                                                                  
All Asset Allocation                           571,946      684,468      600,615      492,730    204,572
------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                           --           --           --           --         --
------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                         --           --           --           --         --
------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation                    --           --           --           --         --
------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                             --           --           --           --         --
------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                        --           --           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap Growth               --           --           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity                 73,324       76,278           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income               458,184      481,560      408,003      239,493     82,561
------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible                 40,077       41,217           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                        --           --           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                           1,073,917           --           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions              114,393      118,242      117,926       38,541         --
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                 1,023,043    1,143,854    1,097,488      756,306    311,226
------------------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity                  219,291           --           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond Index               --           --           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                             --           --           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income             1,103,903           --           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                               508,220           --           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                               --           --           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/Money Market                              1,099,869    1,052,098           --           --         --
------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                  1,361,636    1,685,752    1,581,734    1,198,093      392,688
------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth                    --           --           --           --           --
------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                      359,919      446,362      457,385      319,045      143,483
------------------------------------------------------------------------------------------------------------
EQ/Small Company Index                              --           --           --           --           --
------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                       260,211      272,117      270,546      191,851       91,127
------------------------------------------------------------------------------------------------------------
Franklin Income Securities Fund                416,536      328,984      247,404      116,756           --
------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities           171,880      146,067      158,869       98,376           --
------------------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund            83,552       79,714       84,428       68,229       23,757
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care                128,350      130,612      133,944       89,624       34,314
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity Portfolio     251,427      277,293      268,706      208,605       53,212
------------------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                    75,551       80,630       89,696       58,966       23,622
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio             335,485      220,717      182,506      136,171       32,480
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio          698,959      698,879      723,025      546,239      174,311
------------------------------------------------------------------------------------------------------------
MFS(R) Utilities Series                        195,895      171,034      134,931       72,426       18,209
------------------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond                 482,385           --           --           --           --
------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                  478,312      503,409      553,406      407,080      142,861
------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities Fund/VA          449,536      419,429      330,561       95,923           --
------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)               381,670      391,686      381,980      222,104       53,299
------------------------------------------------------------------------------------------------------------
ProFund VP Bear                                  8,292        7,569       13,091        4,960           --
------------------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity            609,227      613,062      617,666      528,778           --
------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                            90,284       82,491       89,655       53,814           --
------------------------------------------------------------------------------------------------------------




                               APPENDIX II: CONDENSED FINANCIAL INFORMATION II-3








-----------------------------------------------------------------------------------------------------
                                                        UNIT VALUE
                                    -----------------------------------------------------------------
                                         DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 2                                  2010       2009       2008       2007
-----------------------------------------------------------------------------------------------------
                                                              
All Asset Allocation                     $  11.36   $  10.05   $  8.10    $  11.84
-----------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                    8.31       7.47      5.97        9.99
-----------------------------------------------------------------------------------------------------
AXA Conservative Allocation                 10.28       9.75      9.03       10.32
-----------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation             9.73       9.08      8.07       10.19
-----------------------------------------------------------------------------------------------------
AXA Moderate Allocation                      9.40       8.70      7.56       10.18
-----------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                 8.92       8.13      6.78       10.11
-----------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap              12.11       9.22      6.89       12.64
 Growth
-----------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity             10.63       9.63      7.52       12.06
-----------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income            11.62      10.21      9.31       13.99
-----------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible              9.09       8.21      6.38       11.85
-----------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                12.46      10.92      8.43       14.17
-----------------------------------------------------------------------------------------------------
EQ/Core Bond Index                          12.72      12.20     12.06       13.44
-----------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions           13.58      12.60     10.99       12.97
-----------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                23.33      17.89     12.86       18.87
-----------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity               25.50      23.23     15.72       37.39
-----------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond             11.60      11.29        --          --
 Index
-----------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                      8.52       7.68      6.47       11.55
-----------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income            11.90      10.28      8.83       14.13
-----------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                            13.56      10.94      8.14       16.29
-----------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                       13.51      11.22        --          --
-----------------------------------------------------------------------------------------------------
EQ/Money Market                             10.44      10.61     10.76       10.69
-----------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                 10.67      10.03      7.86       11.92
-----------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth            12.33       9.46      6.11       11.77
-----------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                   12.01      12.12     11.41       12.10
-----------------------------------------------------------------------------------------------------
EQ/Small Company Index                      17.32      13.97     11.24       17.31
-----------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                    11.02       9.91      7.61       12.91
-----------------------------------------------------------------------------------------------------
Franklin Income Securities Fund             15.98      14.43     10.82       15.65
-----------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities        14.23      12.00     10.40       14.51
-----------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund         5.71       5.27      4.21       10.55
-----------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care             11.85      11.45      9.12       13.00
-----------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity            10.77       9.87      8.66       14.71
 Portfolio
-----------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                 9.67       8.11      5.24        9.61
-----------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio          15.95      15.23     10.61       19.38
-----------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio       29.27      23.81     13.53       28.80
-----------------------------------------------------------------------------------------------------
MFS(R) Utilities Series                     24.41      21.81     16.66       27.18
-----------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond              12.16      11.57     10.71       14.20
-----------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth               11.78       9.39      7.10       12.48
-----------------------------------------------------------------------------------------------------
Oppenheimer Global Securities               20.05      17.63     12.87       21.93
 Fund/VA
-----------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)            18.15      16.53     14.39       14.76
-----------------------------------------------------------------------------------------------------
ProFund VP Bear                              5.36       6.63      9.35        6.80
-----------------------------------------------------------------------------------------------------




-----------------------------------------------------------------------------------------------------
                                                             UNIT VALUE
                                    -----------------------------------------------------------------
                                         DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 2                                  2006       2005       2004       2003       2002
-----------------------------------------------------------------------------------------------------
                                                                      
All Asset Allocation                     $  11.52   $  10.63   $  10.29   $  9.64    $  8.11
-----------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                      --         --         --        --         --
-----------------------------------------------------------------------------------------------------
AXA Conservative Allocation                    --         --         --        --         --
-----------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation               --         --         --        --         --
-----------------------------------------------------------------------------------------------------
AXA Moderate Allocation                        --         --         --        --         --
-----------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                   --         --         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap                 --         --         --        --         --
 Growth
-----------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity             12.12      10.20         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income            13.72      12.03      11.52      9.94       7.99
-----------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible             10.75      10.39         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                   --         --         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/Core Bond Index                          13.22         --         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions           12.76      11.57      11.26     10.87         --
-----------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                17.56      15.03      14.65     12.33       9.12
-----------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity               26.72         --         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond                --         --         --        --         --
 Index
-----------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                        --         --         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income            13.85         --         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                            15.30         --         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                          --         --         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/Money Market                             10.36      10.06         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                 10.03       9.46       9.12      8.92       7.75
-----------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth               --         --         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                   11.04      11.18      11.29     10.96      10.55
-----------------------------------------------------------------------------------------------------
EQ/Small Company Index                         --         --         --        --         --
-----------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                    12.98      11.57      10.80      9.70       7.73
-----------------------------------------------------------------------------------------------------
Franklin Income Securities Fund             15.34      13.20      13.21     11.80         --
-----------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities        15.17      13.18      12.96     11.87         --
-----------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund        13.79      12.05      11.57     10.83       8.50
-----------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care             11.82      11.43      10.75     10.16       8.09
-----------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity            14.03      11.77      11.32     10.14       7.99
 Portfolio
-----------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                 9.08       8.35       8.32      7.90       5.98
-----------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio          14.43      13.45      12.16     10.48       8.87
-----------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio       22.89      15.87      12.24     10.49       7.93
-----------------------------------------------------------------------------------------------------
MFS(R) Utilities Series                     21.62      16.75      14.58     11.39       8.53
-----------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond              13.97         --         --        --         --
-----------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth               12.24      11.29      10.68      9.65       7.98
-----------------------------------------------------------------------------------------------------
Oppenheimer Global Securities               21.03      18.23      16.25     13.91         --
 Fund/VA
-----------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)            13.68      13.30      14.48     13.32      11.84
-----------------------------------------------------------------------------------------------------
ProFund VP Bear                              6.87       7.56       7.79      8.84         --
-----------------------------------------------------------------------------------------------------



II-4 APPENDIX II: CONDENSED FINANCIAL INFORMATION








-----------------------------------------------------------------------------------------------------
                                                       UNIT VALUE
                                ---------------------------------------------------------------------
                                       DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 2                                2010       2009       2008       2007
-----------------------------------------------------------------------------------------------------
                                                              
ProFund VP Rising Rates Opportunity       5.57       6.75       5.19       8.52
-----------------------------------------------------------------------------------------------------
ProFund VP UltraBull                      9.27       7.72       5.43      16.94
-----------------------------------------------------------------------------------------------------




-----------------------------------------------------------------------------------------------------
                                                           UNIT VALUE
                                ---------------------------------------------------------------------
                                       DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 2                                2006       2005       2004       2003       2002
-----------------------------------------------------------------------------------------------------
                                                                   
ProFund VP Rising Rates Opportunity       9.14       8.44       9.32       10.64     --
-----------------------------------------------------------------------------------------------------
ProFund VP UltraBull                     17.09      14.12      14.00       12.15     --
-----------------------------------------------------------------------------------------------------




                               APPENDIX II: CONDENSED FINANCIAL INFORMATION II-5







-------------------------------------------------------------------------------------------------------------------
                                                            UNITS OUTSTANDING
-------------------------------------------------------------------------------------------------------------------
 Option 2                                    Dec. 31,    Dec. 31,     Dec. 31,     Dec. 31,
                                               2010        2009         2008         2007
-------------------------------------------------------------------------------------------------------------------
                                                                        
All Asset Allocation                         312,126      348,568      422,018      497,752
-------------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                     35,161       78,989      108,793       25,166
-------------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                   46,978       60,616       57,009       33,148
-------------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation              49,080       61,986      138,523       82,083
-------------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                      460,554      473,846      284,753       87,026
-------------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                 239,230      332,932      233,785      179,231
-------------------------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap Growth         61,103       85,165      110,121      143,655
-------------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity              218,864      285,518      296,279      358,489
-------------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income             243,386      280,823      356,589      432,755
-------------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible               14,911       26,052       35,479       42,384
-------------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                  73,927       75,986      103,379      119,932
-------------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                           789,657    1,006,718    1,022,385    1,327,404
-------------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions             76,681       85,065      122,990      152,474
-------------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                 490,470      600,662      733,202      924,400
-------------------------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity                 99,042      131,751      148,122      184,157
-------------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond Index        453,764      549,968           --           --
-------------------------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                       58,018       67,764       98,849      142,380
-------------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income             437,515      525,039      662,750      853,495
-------------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                             303,478      386,610      505,582      630,181
-------------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                        527,298      683,891           --           --
-------------------------------------------------------------------------------------------------------------------
EQ/Money Market                              676,146      814,956      804,101      580,027
-------------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                  602,366      777,279      945,627    1,195,392
-------------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth             383,207      462,363      557,677      681,613
-------------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                    359,592      462,074      441,573      448,175
-------------------------------------------------------------------------------------------------------------------
EQ/Small Company Index                       105,181      123,018      145,865      175,276
-------------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                     161,882      209,472      238,464      277,764
-------------------------------------------------------------------------------------------------------------------
Franklin Income Securities Fund              692,744      832,882      951,395    1,274,513
-------------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities         141,788      141,110      179,625      222,750
-------------------------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund          52,949       74,595       57,908       65,020
-------------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care               49,787       85,498      102,900      113,589
-------------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity Portfolio    77,351      103,527      147,450      173,282
-------------------------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                  31,704       56,851       33,691       46,623
-------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio           152,759      204,902      199,847      228,886
-------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio        339,938      413,632      485,146      602,248
-------------------------------------------------------------------------------------------------------------------
MFS(R) Utilities Series                       83,674      122,322      135,905      183,058
-------------------------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond               217,024      259,324      310,015      393,689
-------------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                205,081      286,588      351,830      427,713
-------------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities Fund/VA        185,262      236,035      279,214      371,734
-------------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)             197,051      250,843      298,376      342,780
-------------------------------------------------------------------------------------------------------------------
ProFund VP Bear                                4,088       17,646       61,612        2,003
-------------------------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity           37,748       48,007       52,767       75,763
-------------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                          48,891       56,863       66,255       98,376
-------------------------------------------------------------------------------------------------------------------




-------------------------------------------------------------------------------------------------------------------
                                                                   UNITS OUTSTANDING
-------------------------------------------------------------------------------------------------------------------
 Option 2                                     Dec. 31,     Dec. 31,     Dec. 31,     Dec. 31,    Dec. 31,
                                                2006         2005         2004         2003        2002
-------------------------------------------------------------------------------------------------------------------
                                                                                  
All Asset Allocation                           588,516      639,152      630,072      522,037    225,750
-------------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                           --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                         --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation                    --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                             --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                        --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap Growth               --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity                 59,749       62,761           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income               503,174      530,146      468,935      268,992    114,840
-------------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible                 39,749       39,883           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                        --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                           1,186,120           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions              158,142      132,522      109,352       39,335         --
-------------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                 1,036,914    1,167,441    1,150,083      900,245    527,141
-------------------------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity                  178,447           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond Index               --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                             --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income               977,862           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                               568,855           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                               --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/Money Market                                584,835      792,861           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                  1,424,361    1,660,838    1,564,074    1,219,870    488,730
-------------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth                    --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                      520,580      703,323      728,549      622,933    267,405
-------------------------------------------------------------------------------------------------------------------
EQ/Small Company Index                              --           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                       344,841      355,846      344,413      294,667    180,021
-------------------------------------------------------------------------------------------------------------------
Franklin Income Securities Fund                474,042      372,282      305,097      127,569         --
-------------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities           208,165      182,562      171,242       72,994         --
-------------------------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund            79,115       85,675       86,053       75,930     41,101
-------------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care                146,760      155,532      165,621      140,052     91,838
-------------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity Portfolio     200,547      242,058      239,554      181,040     67,913
-------------------------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                    48,598       46,447       52,034       33,467     24,267
-------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio             244,138      229,728      203,433      140,717     57,811
-------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio          626,622      639,223      657,169      467,730    231,583
-------------------------------------------------------------------------------------------------------------------
MFS(R) Utilities Series                        167,461      176,163      137,465       79,773     37,190
-------------------------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond                 424,180           --           --           --         --
-------------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                  525,434      540,197      538,881      430,208    249,366
-------------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities Fund/VA          395,586      377,484      313,678      112,568         --
-------------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)               374,179      409,365      412,145      303,678     99,887
-------------------------------------------------------------------------------------------------------------------
ProFund VP Bear                                  3,098        4,277        4,994        1,052         --
-------------------------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity             98,446      116,343      135,919       85,507         --
-------------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                            94,866      116,832      118,709       66,123         --
-------------------------------------------------------------------------------------------------------------------




II-6 APPENDIX II: CONDENSED FINANCIAL INFORMATION








------------------------------------------------------------------------------------------------------------
                                                        UNIT VALUE
                                  --------------------------------------------------------------------------
                                         DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 3                                  2010       2009       2008       2007
------------------------------------------------------------------------------------------------------------
                                                              
All Asset Allocation                     $  10.82   $  9.63    $  7.82    $  11.50
------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                    8.12      7.35       5.91        9.95
------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                 10.05      9.59       8.94       10.28
------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation             9.51      8.93       7.99       10.15
------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                      9.18      8.56       7.49       10.15
------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                 8.71      8.00       6.71       10.07
------------------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap              11.65      8.93       6.72       12.40
 Growth
------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity             10.27      9.37       7.36       11.88
------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income            10.96      9.70       8.90       13.46
------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible              8.78      7.99       6.25       11.68
------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                11.74     10.35       8.04       13.61
------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                          11.97     11.55      11.49       12.88
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions           12.42     11.60      10.18       12.10
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                22.28     17.20      12.45       18.38
------------------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity               24.52     22.48      15.31       36.66
------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond             10.95     10.73         --          --
 Index
------------------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                      8.39      7.61       6.46       11.60
------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income            10.95      9.52       8.23       13.25
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                            12.95     10.51       7.88       15.87
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                       13.39     11.19         --          --
------------------------------------------------------------------------------------------------------------
EQ/Money Market                             10.08     10.31      10.53       10.53
------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                 10.12      9.58       7.56       11.53
------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth            10.79      8.33       5.42       10.50
------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                   11.31     11.48      10.88       11.61
------------------------------------------------------------------------------------------------------------
EQ/Small Company Index                      16.49     13.38      10.84       16.80
------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                    10.57      9.57       7.40       12.63
------------------------------------------------------------------------------------------------------------
Franklin Income Securities Fund             15.23     13.84      10.45       15.21
------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities        13.16     11.17       9.74       13.68
------------------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund         5.52      5.12       4.12       10.39
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care             11.08     10.78       8.64       12.39
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity            10.12      9.34       8.24       14.10
 Portfolio
------------------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                10.12      8.54       5.55       10.25
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio          15.08     14.50      10.17       18.69
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio       27.57     22.57      12.91       27.66
------------------------------------------------------------------------------------------------------------
MFS(R) Utilities Series                     21.60     19.43      14.93       24.52
------------------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond              11.55     11.06      10.30       13.76
------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth               10.99      8.81       6.71       11.86
------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities               17.01     15.05      11.05       18.97
 Fund/VA
------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)            17.30     15.86      13.90       14.35
------------------------------------------------------------------------------------------------------------
ProFund VP Bear                              4.65      5.80       8.23        6.02
------------------------------------------------------------------------------------------------------------



------------------------------------------------------------------------------------------------------------
                                                             UNIT VALUE
                                         DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 3                                  2006       2005       2004       2003       2002
                                                                      
All Asset Allocation                     $  11.26   $  10.46   $  10.19   $  9.60    $  8.13
------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                      --         --         --        --         --
------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                    --         --         --        --         --
------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation               --         --         --        --         --
------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                        --         --         --        --         --
------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                   --         --         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap                 --         --         --        --         --
 Growth
------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity             12.02      10.18         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income            13.29      11.73      11.30      9.82       7.93
------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible             10.66      10.37         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                   --         --         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                          12.76         --         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions           11.98      10.93      10.71     10.40         --
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                17.21      14.83      14.55     12.32       9.18
------------------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity               26.37         --         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond                --         --         --        --         --
 Index
------------------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                        --         --         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income            13.08         --         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                            15.00         --         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                          --         --         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/Money Market                             10.27      10.04         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                  9.77       9.27       9.00      8.85       7.74
------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth               --         --         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                   10.67      10.87      11.05     10.79      10.46
------------------------------------------------------------------------------------------------------------
EQ/Small Company Index                         --         --         --        --         --
------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                    12.79      11.47      10.78      9.74       7.82
------------------------------------------------------------------------------------------------------------
Franklin Income Securities Fund             15.01      13.00      13.09     11.77         --
------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities        14.39      12.58      12.45     11.49         --
Invesco V.I. Financial Services Fund        13.68      12.02      11.63     10.95       8.65
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care             11.35      11.04      10.45      9.94       7.96
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity            13.54      11.43      11.06      9.98       7.92
 Portfolio
------------------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                 9.74       9.03       9.04      8.65       6.59
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio          14.01      13.14      11.95     10.37       8.83
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio       22.12      15.44      11.98     10.34       7.86
------------------------------------------------------------------------------------------------------------
MFS(R) Utilities Series                     19.63      15.31      13.41     10.55       7.94
------------------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond              13.62         --         --        --         --
------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth               11.72      10.88      10.35      9.42       7.84
------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities               18.31      15.87      14.33     12.34         --
 Fund/VA
------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)            13.39      13.10      14.36     13.29      11.89
------------------------------------------------------------------------------------------------------------
ProFund VP Bear                              6.13       6.78       7.04      8.03         --
------------------------------------------------------------------------------------------------------------



                               APPENDIX II: CONDENSED FINANCIAL INFORMATION II-7







------------------------------------------------------------------------------------------------------------
                                                          UNIT VALUE
                                   -------------------------------------------------------------------------
                                           DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 3                                    2010       2009       2008       2007
------------------------------------------------------------------------------------------------------------
                                                                  
ProFund VP Rising Rates Opportunity           5.29       6.45       5.00       8.25
------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                         10.02       8.40       5.94      18.67
------------------------------------------------------------------------------------------------------------




------------------------------------------------------------------------------------------------------------
                                                           UNIT VALUE
                                   -------------------------------------------------------------------------
                                       DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,   DEC. 31,
 OPTION 3                                2006       2005       2004       2003       2002
------------------------------------------------------------------------------------------------------------
                                                                   
ProFund VP Rising Rates Opportunity       8.91       8.28       9.20       10.57     --
------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                     18.95      15.77      15.73       13.74     --
------------------------------------------------------------------------------------------------------------




II-8 APPENDIX II: CONDENSED FINANCIAL INFORMATION







------------------------------------------------------------------------------------------------------------
                                                          UNITS OUTSTANDING
                                     -----------------------------------------------------------------------
Option 3                                     Dec. 31,   Dec. 31,   Dec. 31,   Dec. 31,
                                               2010       2009       2008       2007
------------------------------------------------------------------------------------------------------------
                                                                  
All Asset Allocation                         151,771    174,411    216,521    254,235
------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                     40,573     37,046     17,830     34,138
------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                   77,068     17,467      5,709          -
------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation              38,715     28,089     15,344      8,553
------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                      125,067    143,749     88,659     50,097
------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                 129,275     98,028     91,336    101,843
------------------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap Growth         81,971     90,660    119,708    118,648
------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity              198,047    208,484    225,245    249,281
------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income             223,501    270,840    285,462    340,231
------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible               11,121     15,293     27,274     30,193
------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                  58,908     68,895     75,551     88,898
------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                           549,335    645,684    554,830    659,415
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions             78,893     87,045    100,229    110,532
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                 340,106    404,191    457,808    555,475
------------------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity                 87,875    108,954    119,794    131,877
------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond Index        376,543    421,835         --         --
------------------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                       70,725     76,434     85,550    104,475
------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income             326,836    374,126    457,511    524,111
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                             339,741    379,519    447,586    513,390
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                        302,196    351,453         --         --
------------------------------------------------------------------------------------------------------------
EQ/Money Market                              557,453    696,885    542,948    644,650
------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                  456,311    547,724    616,988    740,646
------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth             292,866    356,085    387,830    462,277
------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                    150,539    202,811    150,857    119,459
------------------------------------------------------------------------------------------------------------
EQ/Small Company Index                        45,489     69,833     89,275     94,407
------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                     175,553    192,521    178,458    212,333
------------------------------------------------------------------------------------------------------------
Franklin Income Securities Fund              380,714    438,894    516,649    639,433
------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities         103,576    109,550    121,162    130,496
------------------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund          75,761     78,034     79,897     83,028
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care               84,358     92,452    110,759    128,499
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity Portfolio    58,465     63,870     95,468    106,061
------------------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                  29,419     30,791     42,232     41,117
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio            97,193    124,266    142,574    157,757
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio        287,233    345,320    442,783    518,962
------------------------------------------------------------------------------------------------------------
MFS(R) Utilities Series                       71,204     91,752     99,733    110,435
------------------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond               149,629    162,634    172,340    211,992
------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                194,598    228,267    298,509    365,192
------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities Fund/VA        113,820    131,009    151,724    179,536
------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)             122,178    133,700    161,765    170,551
------------------------------------------------------------------------------------------------------------
ProFund VP Bear                                5,516     10,113     20,500      6,114
------------------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity           36,458     39,524     40,075     56,817
------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                         125,003    162,969    196,300    132,356
------------------------------------------------------------------------------------------------------------




------------------------------------------------------------------------------------------------------------
                                                                  UNITS OUTSTANDING
                                     -----------------------------------------------------------------------
Option 3                                      Dec. 31,     Dec. 31,     Dec. 31,    Dec. 31,   Dec. 31,
                                                2006         2005         2004        2003       2002
------------------------------------------------------------------------------------------------------------
                                                                                
All Asset Allocation                           279,059      304,351      329,211    264,065    130,971
------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                           --           --           --         --         --
------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                         --           --           --         --         --
------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation                    --           --           --         --         --
------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                             --           --           --         --         --
------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                        --           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/AllianceBernstein Small Cap Growth               --           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity                 66,466       55,843           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income               393,271      450,085      443,355    210,340     85,624
------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible                 25,282       27,434           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                        --           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                             491,298           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions              147,362      152,240      142,384     19,602         --
------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                   655,604      745,939      771,937    570,622    312,519
------------------------------------------------------------------------------------------------------------
EQ/Global Multi-Sector Equity                  158,960           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond Index               --           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/Large Cap Value PLUS                             --           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income               547,148           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                               478,745           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                               --           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/Money Market                                485,349      525,734           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                  1,028,742    1,254,424    1,231,095    903,450    322,138
------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth                    --           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                      140,823      163,210      172,435    132,055     58,455
------------------------------------------------------------------------------------------------------------
EQ/Small Company Index                              --           --           --         --         --
------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                       272,190      284,955      288,655    205,585    116,862
------------------------------------------------------------------------------------------------------------
Franklin Income Securities Fund                136,586      130,576      149,633     53,664         --
------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities           150,943      129,608      127,851     25,163         --
------------------------------------------------------------------------------------------------------------
Invesco V.I. Financial Services Fund            85,887       93,977       91,928     58,614     19,438
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Health Care                141,522      160,443      165,597    117,180     31,890
------------------------------------------------------------------------------------------------------------
Invesco V.I. Global Value Equity Portfolio     142,928      137,508      138,208    107,025     96,503
------------------------------------------------------------------------------------------------------------
Invesco V.I. Technology Fund                    60,685       61,622       68,906     40,774     15,037
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio             141,545      137,929      133,787    103,426     40,704
------------------------------------------------------------------------------------------------------------
Janus Aspen Series Overseas Portfolio          580,743      582,650      605,704    443,160    191,763
------------------------------------------------------------------------------------------------------------
MFS(R) Utilities Series                        114,401      123,861      108,933     53,404     13,481
------------------------------------------------------------------------------------------------------------
Multimanager Multi-Sector Bond                 247,892           --           --         --         --
------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                  428,335      462,017      484,221    381,741    174,101
------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities Fund/VA          193,323      212,652      206,632     53,888         --
------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)               195,938      229,087      267,365    194,076     50,418
------------------------------------------------------------------------------------------------------------
ProFund VP Bear                                 10,309       12,635       12,064      5,843         --
------------------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity            106,074      120,988      155,028     47,641         --
------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                           144,606      178,819      221,408    131,565         --
------------------------------------------------------------------------------------------------------------




                               APPENDIX II: CONDENSED FINANCIAL INFORMATION II-9



Statement of additional information


--------------------------------------------------------------------------------
TABLE OF CONTENTS


MAY 1, 2011



                                                                            PAGE

Additional information about the Company                                       2

About our independent registered public accounting firm                        2

Sale of the contracts                                                          2

Federal tax status                                                             2

Financial statements                                                           4


If you would like to receive a copy of the MONY America Variable Account A
Statement of Additional Information, please return this request to:

MONY Life Insurance Company of America
Policyholder Services
100 Madison Street
Syracuse, New York 13202
1-800-487-6669


www.axa-equitable.com


Please send me a copy of the MONY America Variable Account A Statement of
Additional Information.


--------------------------------------------------------------------------------
Name


--------------------------------------------------------------------------------
Address


--------------------------------------------------------------------------------
City                                            State           Zip



                                                                           X2868

                                                                          MLA-VA





Individual Flexible Payment Variable
Annuity Contract

Issued by MONY Life Insurance Company of America with variable investment
options under MONY America's MONY America Variable Account A


PROSPECTUS DATED MAY 1, 2011


Please read and keep this prospectus for future reference. It contains
important information that you should know before purchasing, or taking any
other action under your contract. Also, you should read the prospectuses for
each Trust, which contain important information about their portfolios.


--------------------------------------------------------------------------------


MONY Life Insurance Company of America (the "Company") issues the flexible
payment variable annuity contract described in this prospectus. This prospectus
is a disclosure document and describes all of the contract's material features,
benefits, rights and obligations, as well as other information. The description
of the contract's material provisions in this prospectus is current as of the
date of this prospectus. If certain material provisions under the contract are
changed after the date of this prospectus in accordance with the contract,
those changes will be described in a supplement to this prospectus. You should
carefully read this prospectus in conjunction with any applicable supplements.


This Contract is no longer being sold. This prospectus is used with current
contract owners only. We will continue to accept Purchase Payments under
existing Contracts. You should note that your Contract features and charges,
and your investment options, may vary depending on your state and/or the date
on which you purchased your Contract. For more information about the particular
features, charges and options applicable to you, please contact your financial
professional and/or refer to your Contract.

You can tell us what to do with your Purchase Payments. You can also tell us
what to do with the fund value your Contract may create for you resulting from
those Purchase Payments.

You may allocate some or all of your Purchase Payments into the subaccounts.
Each subaccount is a subaccount of Separate Account MONY America Variable
Account A. Both the value of your Contract before annuitization and the amount
of income afterward will depend on the investment performance of the portfolios
you select. You bear the investment risk of investing in the portfolios. The
subaccounts invest in shares of the following portfolios of AXA Premier VIP
Trust, Dreyfus Stock Index Fund, Inc., EQ Advisors Trust, Fidelity Variable
Insurance Products (VIP), Franklin Templeton Variable Insurance Products Trust,
Janus Aspen Series, Oppenheimer Variable Account Funds, PIMCO Variable
Insurance Trust and ProFunds VP (the "Funds").




--------------------------------------------------------------------------------
SUBACCOUNTS
--------------------------------------------------------------------------------
                                      
o All Asset Allocation                   o EQ/Money Market
o AXA Aggressive Allocation(1)           o EQ/Montag & Caldwell Growth
o AXA Conservative Allocation(1)         o EQ/Morgan Stanley Mid Cap Growth
o AXA Conservative-Plus Allocation(1)    o EQ/PIMCO Ultra Short Bond
o AXA Moderate Allocation(1)             o EQ/Quality Bond PLUS
o AXA Moderate-Plus Allocation(1)        o EQ/T. Rowe Price Growth Stock
o Dreyfus Stock Index                    o EQ/UBS Growth and Income
o EQ/BlackRock Basic Value Equity        o Fidelity VIP Contrafund(R)
o EQ/Boston Advisors Equity Income       o Franklin Income Securities
o EQ/Calvert Socially Responsible        o Franklin Rising Dividends Securities
o EQ/Capital Guardian Research           o Janus Aspen Balanced
o EQ/Core Bond Index                     o Janus Aspen Enterprise
o EQ/Equity Growth PLUS                  o Janus Aspen Forty
o EQ/GAMCO Mergers and Acquisitions      o Janus Aspen Worldwide
o EQ/GAMCO Small Company Value           o Multimanager Small Cap Growth
o EQ/Intermediate Government Bond        o Oppenheimer Global Securities
   Index                                  Fund/VA
o EQ Large Cap Value Index(2)            o PIMCO VIT Global Bond (Unhedged)
o EQ/Lord Abbett Growth and Income (3)   o ProFund VP Bear
o EQ/MFS International Growth(4)         o ProFund VP Rising Rates Opportunity
o EQ/Mid Cap Index                       o ProFund VP UltraBull
o EQ/Mid Cap Value PLUS
--------------------------------------------------------------------------------





NOT ALL OF THESE PORTFOLIOS MAY BE AVAILABLE IN ALL STATES OR ALL MARKETS.
(1)  The "AXA Allocation" portfolios.
(2)  This variable investment option will become available on or about
     May 20, 2011. Please see "The Funds" later in this Prospectus for more
     information about this variable investment option.
(3)  Please see "The Funds" later in this Prospectus regarding the proposed
     merger of this variable investment option on or about May 20, 2011.
(4)  This is the variable investment option's new name, effective on or about
     May 20, 2011, subject to regulatory approval. Please see "The Funds" later
     in this prospectus for the variable investment option's former name.



THE SEC HAS NOT APPROVED OR DISAPPROVED THESE SECURITIES OR DETERMINED IF THIS
PROSPECTUS IS ACCURATE OR COMPLETE. ANY REPRESENTATION TO THE CONTRARY IS A
CRIMINAL OFFENSE. THE CONTRACTS ARE NOT INSURED BY THE FDIC OR ANY OTHER
AGENCY. THEY ARE NOT DEPOSITS OR OTHER OBLIGATIONS OF ANY BANK AND ARE NOT BANK
GUARANTEED. THEY ARE SUBJECT TO INVESTMENT RISKS AND POSSIBLE LOSS OF
PRINCIPAL.

                                                                          e13455
                                                                          MLA-CM




You may also allocate some or all of your Purchase Payments and fund value into
our Guaranteed Interest Account with Market Value Adjustment, which is
discussed later in this Prospectus.

Among the many terms of the Guaranteed Interest Account with Market Value
Adjustment are:

o    Guaranteed interest to be credited for specific periods (referred to as
     "Accumulation Periods").

o    Three (3), five (5), seven (7), and ten (10) year Accumulation Periods are
     available. The one (1) year Accumulation Period is limited to the
     following states: Maryland, the Commonwealth of Massachusetts, New Jersey,
     Oklahoma, Oregon, the Commonwealth of Pennsylvania, South Carolina, Texas,
     and Washington.

o    Interest will be credited for the entire Accumulation Period on a daily
     basis. Different rates apply to each Accumulation Period and are
     determined by the Company from time to time at its sole discretion.

o    A market value adjustment may be charged if part or all of the Guaranteed
     Interest Account with Market Value Adjustment is surrendered or
     transferred before the end of the Accumulation Period.

o    Contract owners should carefully consider the information contained in this
     prospectus before allocating Purchase Payments or Fund Values to the
     Guaranteed Interest Account with Market Value Adjustment offered herein.
--------------------------------------------------------------------------------
These are only some of the terms of the Guaranteed Interest Account with Market
Value Adjustment. Please read this prospectus carefully for more complete
details of the contract.
--------------------------------------------------------------------------------

A Statement of Additional Information dated May 1, 2011 containing additional
information about the contract is incorporated herein by reference. It has been
filed with the Securities and Exchange Commission and is available from the
Company without charge upon written request. You may request one by writing to
our processing office located at MONY Life Insurance Company of America,
Policyholder Services,100 Madison Street, Syracuse, New York 13202, or by
telephoning 1-800-487-6669 or by accessing the SEC's website at www.sec.gov.
The table of contents of the Statement of Additional Information can be found
in the back of this prospectus.





Contents of this Prospectus


--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
1. SUMMARY OF THE CONTRACT                                                    4
--------------------------------------------------------------------------------
Definitions                                                                   4
Purpose of the Contract                                                       4
Purchase Payments and fund value                                              4
Minimum Purchase Payments                                                     4
MONY America Variable Account A                                               4
Guaranteed Interest Account with Market Value Adjustment                      4
The Accumulation Periods                                                      5
Crediting of interest                                                         5
The Market Value Adjustment                                                   5
Transfer of fund value                                                        5
Contract loans                                                                5
Surrender                                                                     6
Charges and deductions                                                        6
Right to return contract provision                                            6
Death benefit                                                                 6
Fee tables                                                                    7
Example                                                                       7
Other contracts                                                               8
Condensed financial information                                               8


--------------------------------------------------------------------------------
2. WHO IS MONY LIFE INSURANCE COMPANY OF AMERICA?                             9
--------------------------------------------------------------------------------
MONY Life Insurance Company of America                                        9
How to reach us                                                               9
MONY America Variable Account A                                              10


--------------------------------------------------------------------------------
3. THE FUNDS                                                                 11
--------------------------------------------------------------------------------
Purchase of portfolio shares by MONY America Variable Account A              14


--------------------------------------------------------------------------------
4. DETAILED INFORMATION ABOUT THE CONTRACT                                   16
--------------------------------------------------------------------------------
Payment and allocation of Purchase Payments                                  16
Telephone/fax/web transactions                                               19
Disruptive transfer activity                                                 20
Termination of the Contract                                                  21


                                                  CONTENTS OF THIS PROSPECTUS  2





--------------------------------------------------------------------------------
5. DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT
   WITH MARKET VALUE ADJUSTMENT                                              22
--------------------------------------------------------------------------------
General                                                                      22
Guaranteed Interest Account with Market Value Adjustment                     22
Allocations to the Guaranteed Interest Account with Market Value Adjustment  22
Specified interest rates and the accumulation periods                        22
Surrenders, transfers or loans                                               24
The Market Value Adjustment                                                  24
Investments                                                                  25


--------------------------------------------------------------------------------
6. SURRENDERS                                                               26
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
7. LOANS                                                                    27
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
8. DEATH BENEFIT                                                             28
--------------------------------------------------------------------------------
Death benefit provided by the Contract                                       28
Enhanced death benefit options                                               28
Election and effective date of election                                      28
Payment of death benefit                                                     29


--------------------------------------------------------------------------------
9. CHARGES AND DEDUCTIONS                                                    30
--------------------------------------------------------------------------------
Deductions from Purchase Payments                                            30
Charges against Fund Value                                                   30
Deductions from Fund Value                                                   30


--------------------------------------------------------------------------------
10. ANNUITY PROVISIONS                                                       33
--------------------------------------------------------------------------------
Annuity payments                                                             33
Election and change of settlement option                                     33
Settlement options                                                           33
Frequency of annuity payments                                                34
Additional provisions                                                        34
Guaranteed Interest Account at annuitization                                 34


--------------------------------------------------------------------------------
11. OTHER PROVISIONS                                                         35
--------------------------------------------------------------------------------
Ownership                                                                    35
Provision required by Section 72(s) of the Code                              35
Provision required by Section 401(a)(9) of the Code                          35
Secondary annuitant                                                          36
Assignment                                                                   36
Change of beneficiary                                                        36
Substitution of securities                                                   36
Changes to Contracts                                                         36
Change in operation of MONY America Variable Account A                       36


--------------------------------------------------------------------------------
12. VOTING RIGHTS                                                            37
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
13. DISTRIBUTION OF THE CONTRACTS                                            38
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
14. FEDERAL TAX STATUS                                                       40
--------------------------------------------------------------------------------
Introduction                                                                 40

Taxation of annuities in general                                             40

Retirement plans                                                             41
Tax treatment of the Company                                                 41


--------------------------------------------------------------------------------
15. ADDITIONAL INFORMATION AND INCORPORATION OF CERTAIN INFORMATION BY
    REFERENCE                                                                42
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
16. LEGAL PROCEEDINGS                                                        43
--------------------------------------------------------------------------------


--------------------------------------------------------------------------------
17. FINANCIAL STATEMENTS                                                     44
--------------------------------------------------------------------------------

About the general account                                                    44



--------------------------------------------------------------------------------
APPENDIX
--------------------------------------------------------------------------------
    I --   Condensed financial information                                  I-1


--------------------------------------------------------------------------------
STATEMENT OF ADDITIONAL INFORMATION
     TABLE OF CONTENTS
--------------------------------------------------------------------------------



3  CONTENTS OF THIS PROSPECTUS





1. SUMMARY OF THE CONTRACT



--------------------------------------------------------------------------------

This summary provides you with a brief overview of the more important aspects
of your Contract, including the Guaranteed Interest Account with Market Value
Adjustment. It is not intended to be complete. More detailed information is
contained in this prospectus on the pages following this summary and in your
Contract. This summary and the entire prospectus will describe the part of the
contract involving MONY America Variable Account A. The prospectus also briefly
will describe the Guaranteed Interest Account with Market Value Adjustment and
the portfolios offered by AXA Premier VIP Trust, Dreyfus Stock Index Fund,
Inc., EQ Advisors Trust, Fidelity Variable Insurance Products, Franklin
Templeton Variable Insurance Products Trust, Janus Aspen Series, Oppenheimer
Variable Account Funds, PIMCO Variable Insurance Trust and ProFunds VP. See
applicable Fund prospectuses for more detailed information about the portfolios
offered by the Funds.


DEFINITIONS
--------------------------------------------------------------------------------
Specialized terms will be defined on the page where they first appear enclosed
in a box.
--------------------------------------------------------------------------------

PURPOSE OF THE CONTRACT

The Contract is an Individual Flexible Payment Variable Annuity Contract (the
"Contract" or "Contracts"). As of January 31, 2005, we no longer offer this
Contract. We will continue to accept Purchase Payments under existing
Contracts.

The Contract is designed to allow an owner to make Purchase Payments to the
Company under the Contract. Those Purchase Payments are allocated at the
owner's choice among the subaccounts of MONY America Variable Account A and the
Guaranteed Interest Account with Market Value Adjustment. Those Purchase
Payments can accumulate for a period of time and create fund value for the
owner. The owner can choose the length of time that such Purchase Payments may
accumulate. The owner may choose at some point in the future to receive annuity
benefits based upon that accumulated fund value.

An owner may use the Contract's design to accumulate fund value for various
purposes including retirement or to supplement other retirement programs. Some
of these retirement programs (the "Qualified Plans") may qualify for federal
income tax advantages available under certain Sections of the Internal Revenue
Code (the "Code"), Sections 401, 403 (other than Section 403(b)), 408, 408A and
457, for example.

--------------------------------------------------------------------------------
QUALIFIED PLANS -- Retirement plans that may receive favorable tax treatment
under certain Sections of the Internal Revenue Code.
QUALIFIED CONTRACTS -- Contracts issued under Qualified Plans.
NON-QUALIFIED CONTRACTS -- Contracts not issued under Qualified Plans.
--------------------------------------------------------------------------------

The Contract is also designed to allow the owner to request payments of part or
all of the accumulated fund value before the owner begins to receive annuity
benefits. This payment may result in the imposition of a surrender charge and a
market value adjustment. The market value adjustment will not apply to
Contracts issued in certain states. It may also be subject to income and other
taxes.

PURCHASE PAYMENTS AND FUND VALUE

You may allocate your Purchase Payments to one or more of the subaccounts of
MONY America Variable Account A that are available under the Contract and/or to
the Guaranteed Interest Account with Market Value Adjustment. The Purchase
Payments you allocate among the various subaccounts of MONY America Variable
Account A may increase or decrease in value on any day depending on the
investment experience of the subaccounts you select. There is no guarantee that
the value of the Purchase Payments you allocate to any of the subaccounts of
MONY America Variable Account A will increase or that the Purchase Payments you
make will not lose value.

MINIMUM PURCHASE PAYMENTS

The minimum Purchase Payment for individuals varies depending upon the
purchaser of the Contract and the method of paying the Purchase Payments. See
"Payment and allocation of Purchase Payments."

Additional Purchase Payments may be made at any time. However, for certain
automatic payment plans, the smallest additional payment is $50. (See "Issuance
of the Contract.") The Company may change this requirement in the future.

MONY AMERICA VARIABLE ACCOUNT A

MONY America Variable Account A is a separate investment account of MONY Life
Insurance Company of America (the "Company"). MONY America Variable Account A's
assets are owned by the Company, but are not chargeable with liabilities
arising from any other business the Company conducts.

The subaccounts of MONY America Variable Account A invest in shares of the
Funds at their net asset value. (See "The Funds.") Owners bear the entire
investment risk for all amounts allocated to MONY America Variable Account A
subaccounts.

--------------------------------------------------------------------------------
FUND -- Any open-end management investment company or unit investment trust in
which a subaccount invests.
OWNER -- The person so designated in the application to whom all rights,
benefits, options and privileges apply while the Annuitant is living. If a
Contract has been absolutely assigned, the assignee becomes the Owner.
PURCHASE PAYMENT -- An amount paid to the Company by the Owner or on the
Owner's behalf as consideration for the benefits provided by the Contract.
NET PURCHASE PAYMENT -- Purchase Payment less any applicable tax charges.
--------------------------------------------------------------------------------

GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT

The Guaranteed Interest Account with Market Value Adjustment is part of the
Company's General Account. It consists of all the Company's assets other than
assets allocated to segregated investment accounts of the Company. Net Purchase
Payments allocated to the Guaranteed Interest Account with Market Value
Adjustment will be credited with interest at rates guaranteed by the Company
for specified periods. (See "Description of the Guaranteed Interest Account
with Market Value Adjustment.")


                                                      SUMMARY OF THE CONTRACT  4





The Guaranteed Interest Account with Market Value Adjustment is designed to
provide you with an opportunity to receive a guaranteed fixed rate of interest.
You can choose the period of time over which the guaranteed fixed rate of
interest will be paid. That period of time is known as the Accumulation Period.


The Guaranteed Interest Account with Market Value Adjustment is also designed
to provide you with the opportunity to transfer part or all of the Guaranteed
Interest Account with Market Value Adjustment to the Subaccounts available to
you under the Contract. It is also designed to provide you with the opportunity
to surrender part or all of the Guaranteed Interest Account with Market Value
Adjustment before the end of the Accumulation Period. If you ask us to transfer
or surrender part or all of the Guaranteed Interest Account, we may apply a
market value adjustment ("MVA"). This adjustment may be positive, negative, or
zero.

THE ACCUMULATION PERIODS

There are 4 different Accumulation Periods currently available: a 3-year
Accumulation Period, a 5-year Accumulation Period, a 7-year Accumulation
Period, and a 10-year Accumulation Period. Certain states limit contracts to a
1-year Accumulation Period. You may allocate initial or additional Purchase
Payments made under the Contract to one or more Accumulation Periods. You may
also ask us to transfer Fund Values from the Subaccounts available under the
Contract to one or more of the Accumulation Periods. There is no minimum amount
required for allocation or transfer to an Accumulation Period. (See
"Allocations to the Guaranteed Interest Account with Market Value Adjustment.")

Each Accumulation Period starts on the Business Day that falls on, or next
follows, the date on which allocations are made and Purchase Payments are
received or Fund Values are transferred. Each Accumulation Period ends on the
Monthly Contract Anniversary immediately prior to the 3, 5, 7 or 10 year
anniversary of the start of the Accumulation Period (the "Maturity Date"). This
means that the Accumulation Period for a 3, 5, 7 or 10 year Accumulation Period
may be up to 31 days shorter than 3, 5, 7 or 10 years, respectively. (See
"Specified interest rates and the accumulation periods.")

CREDITING OF INTEREST

The Company will credit amounts allocated to an Accumulation Period with
interest at an annual rate not less than 3.50%. This interest rate is referred
to as the Specified Interest Rate. It will be credited for the duration of the
Accumulation Period. Specified Interest Rates for each Accumulation Period are
declared periodically at the sole discretion of the Company. (See "Specified
interest rates and the accumulation periods.")

At least 15 days and at most 45 days prior to the Maturity Date of an
Accumulation Period, Owners having Fund Values allocated to such Accumulation
Periods will be notified of the impending Maturity Date. Owners will then have
the option of directing the surrender or transfer (including transfers for the
purpose of obtaining a Loan) of the Fund Value within 30 days before the end of
the Accumulation Period without application of any MVA.

The Specified Interest Rate will be credited to amounts allocated to an
Accumulation Period, so long as such allocations are neither surrendered nor
transferred prior to the Maturity Date for the Allocation Period. The Specified
Interest Rate is credited daily, providing an annual effective yield. (See
"Specified interest rates and the accumulation periods.")

THE MARKET VALUE ADJUSTMENT

Amounts that are surrendered or transferred (including transfers for the
purpose of obtaining a Loan) from an Accumulation Period more than 30 days
before the Maturity Date will be subject to an MVA. An MVA will not apply upon
payment of a death benefit upon the death of the annuitant. The MVA is
determined through the use of a factor, which is known as the MVA Factor. This
factor is discussed in detail in the section entitled "The Market Value
Adjustment." The MVA could cause an increase or decrease or no change at all in
the amount of the distribution from an Accumulation Period.

A market value adjustment will be imposed on transfers or surrenders (partial
or full) from the Guaranteed Interest Account with Market Value Adjustment in
most states. A MARKET VALUE ADJUSTMENT WILL NOT BE IMPOSED ON CONTRACTS ISSUED
IN THE STATES OF MARYLAND, THE COMMONWEALTH OF MASSACHUSETTS, NEW JERSEY,
OKLAHOMA, OREGON, THE COMMONWEALTH OF PENNSYLVANIA, SOUTH CAROLINA, TEXAS AND
WASHINGTON; HOWEVER, RESTRICTIONS ON TRANSFERS APPLY IN THESE STATES. The
adjustment can be either a positive or negative adjustment. No adjustment is
made for the amount withdrawn or transferred within 30 days before the end of
the accumulation period.

--------------------------------------------------------------------------------
FUND VALUE -- The aggregate dollar value as of any Business Day of all amounts
accumulated under each of the subaccounts, the Guaranteed Interest Account with
Market Value Adjustment, and the Loan Account of the Contract. If the term Fund
Value is preceded or followed by the terms subaccount(s), the Guaranteed
Interest Account with Market Value Adjustment, and the Loan Account, or any one
or more of those terms, Fund Value means only the Fund Value of the subaccount,
the Guaranteed Interest Account with Market Value Adjustment or the Loan
Account, as the context requires.
BUSINESS DAY -- Our "business day" is generally any day the New York Stock
Exchange is open for regular trading and generally ends at 4:00 p.m. Eastern
Time (or as of an earlier close of regular trading). A business day does not
include a day on which we are not open due to emergency conditions determined
by the Securities and Exchange Commission. We may also close early due to such
emergency conditions.
MONTHLY CONTRACT ANNIVERSARY -- The date of each month corresponding to the
Effective Date of the Contract. For example, for a Contract with a June 15
Effective Date, the Monthly Contract Anniversary is the 15th of each month. If
a Contract's Effective Date falls on the 29th, 30th or 31st day of a month, the
Monthly Contract Anniversary will be the earlier of that day or the last day of
the particular month in question.
--------------------------------------------------------------------------------

TRANSFER OF FUND VALUE

You may transfer Fund Value among the subaccounts and to or from the Guaranteed
Interest Account with Market Value Adjustment. Transfers from the Guaranteed
Interest Account with Market Value Adjustment may be subject to a Market Value
Adjustment for contracts issued in certain states. Transfers may be made by
telephone, facsimile or via the web if the proper form has been completed,
signed, and received by the Company at its Operations Center. See the cover
page for how to contact the Operations Center. (See "Transfers.")

CONTRACT LOANS

Under certain qualified contracts, you may borrow up to 50% of your Contract's
Fund Value from the Company. Your Contract will be the only security required
for the loan. Contracts issued to 401(k) plans are generally the only Contracts
which permit loans. An amount equal to


5  SUMMARY OF THE CONTRACT





the amount of the loan is transferred to the loan account as security for the
loan. The loan account is part of the Company's General Account.

We will charge you interest on the amount borrowed. If you do not pay the
interest when due, the amount due will be borrowed from the Contract's Fund
Value.

SURRENDER

You may surrender all or part of the Contract at any time and receive its cash
value while the Annuitant is alive prior to the annuity starting date. We may
impose a surrender charge and market value adjustment (if applicable). The
amounts you receive upon surrender may be subject to income taxes and a 10%
penalty tax if you are younger than 59-1/2 at the time of surrender. (See
"Federal tax status.")

CHARGES AND DEDUCTIONS

The Contract provides for the deduction of various charges and expenses from
the Fund Value of the Contract.

RIGHT TO RETURN CONTRACT PROVISION

This information is no longer applicable, as these contracts are no longer
available to new purchasers.

You have the right to examine the Contract when you receive it. You may return
the Contract for any reason during the "right to return contract period"
(usually within ten days from the day you receive it. You will receive a refund
of the Purchase Payments received by the Company, less any partial surrender
you made. During the right to return contract period, Purchase Payments will be
retained in the Company's General Account and will earn interest at a rate not
less than 3.50% per year. If you have not returned the Contract at the end of
the right to return contract period, we transfer the Net Purchase Payments with
interest to the subaccounts and/or the Guaranteed Interest Account.

DEATH BENEFIT

If the Annuitant (and the Secondary Annuitant, if any) dies before the annuity
starting date a death benefit will be payable to the Beneficiary. Under certain
circumstances, an enhanced death benefit may be payable. If the Annuitant dies
after annuity payments start, no death benefit is payable except as may be
payable under the settlement option selected. (See "Death benefit" and
"Enhanced death benefit.")

--------------------------------------------------------------------------------
ANNUITANT -- The person upon whose continuation of life any annuity payment
depends.
SECONDARY ANNUITANT -- The party designated by the Owner to become the
Annuitant, subject to certain conditions, on the death of the Annuitant.
BENEFICIARY -- The party entitled to receive benefits payable at the death of
the Annuitant or (if applicable) the Secondary Annuitant.
ANNUITY STARTING DATE -- Attainment of age 95, or at the discretion of the
Owner of the Contract, a date that is at least ten years from the Effective
Date of the Contract.
--------------------------------------------------------------------------------


                                                      SUMMARY OF THE CONTRACT  6





FEE TABLES

The following tables describe the fees and expenses that you will pay when
buying, owning, and surrendering the Contract.

The first table describes the fees and expenses that you will pay at the time
that you buy the Contract, surrender the Contract, transfer Fund Value between
investment options, or for Contracts funding 401(k) plans only, take a loan. A
charge for taxes may also be deducted.



                                                                                        
----------------------------------------------------------------------------------------------------------
OWNER TRANSACTION EXPENSES:
----------------------------------------------------------------------------------------------------------
Maximum deferred sales load (surrender charge) (as a percentage of                          7.00%(1)
Purchase Payments surrendered)
----------------------------------------------------------------------------------------------------------
Loan interest spread (effective annual rate)                                                2.50%(2)
----------------------------------------------------------------------------------------------------------
Maximum transfer charge                                                                     $  25(3)
----------------------------------------------------------------------------------------------------------
The next table describes the fees and expense that you will pay periodically during the time that you own
the Contract, not including Fund portfolio company fees and expenses.
----------------------------------------------------------------------------------------------------------
Maximum annual contract charge                                                              $  50(4)
----------------------------------------------------------------------------------------------------------
SEPARATE ACCOUNT ANNUAL EXPENSES (AS A PERCENTAGE OF AVERAGE ANNUAL FUND VALUE IN MONY AMERICA VARIABLE
ACCOUNT A):
----------------------------------------------------------------------------------------------------------
Maximum mortality and expense risk fees                                                     1.35%(5)
----------------------------------------------------------------------------------------------------------
Total separate account annual expenses                                                      1.35%(5)
----------------------------------------------------------------------------------------------------------


(1) The surrender charge percentage, which reduces to zero, is determined under
    a surrender charge schedule. (See "Deductions from fund value -- Amount of
    surrender charge.") The surrender charge may be reduced under certain
    circumstances which include reduction in order to guarantee that certain
    amounts may be received free of surrender charge. (See "Charges against fund
    value -- Free partial surrender amount.")
(2) The loan interest spread is the difference between the amount of interest we
    charge on loans and the amount of interest we credit to amounts held in the
    loan account to secure loans.
(3) The transfer charge currently is $0. However, the Company has reserved the
    right to impose a charge for each transfer, which will not exceed $25
    (except for Contracts issued in the states of South Carolina and Texas where
    it will not exceed $10). (See "Charges against fund value -- Transfer
    charge.")
(4) The annual contract charge is currently $0. However, the Company may in the
    future change the amount of the charge to an amount not exceeding $50 per
    contract year (except for contracts issued in the states of Maryland,
    Massachusetts, New Jersey, Oklahoma, Oregon, Commonwealth of Pennsylvania,
    South Carolina, Texas and Washington where the charge may not exceed $30).
    (See "Charges against fund value -- Annual contract charge.")
(5) The mortality and expense risk charge is deducted daily equivalent to a
    current annual rate of 1.35% (and is guaranteed not to exceed a daily rate
    equivalent to an annual rate of 1.35%) from the value of the net assets of
    MONY America Variable Account A.


The next item shows the minimum and maximum total operating expenses charged by
the portfolio companies for the year ended December 31, 2010. You may pay
portfolio company operating expenses periodically during the time that you own
the Contract. Certain variable investment options invest in a corresponding
portfolio of one of the Trusts or other unaffiliated investment companies. Each
portfolio, in turn, invests in shares of other portfolios of the Trusts and/or
shares of unaffiliated portfolios ("underlying portfolios"). More detail
concerning each Fund portfolio company's fees and expenses is contained in the
prospectus for each portfolio.





                                                                                             
------------------------------------------------------------------------------------------------------------
TOTAL ANNUAL FUND PORTFOLIO OPERATING EXPENSES                                          LOWEST     HIGHEST
------------------------------------------------------------------------------------------------------------
Total Annual Portfolio Operating Expenses for 2010 (expenses that are deducted           0.27%      1.78%
from  portfolio assets including management fees, 12b-1 fees, service fees,
and/or other expenses)(1)
------------------------------------------------------------------------------------------------------------




(1) "Total Annual Portfolio Operating Expenses" are based, in part, on estimated
    amounts for options added during the fiscal year 2010 and for the underlying
    portfolios. In addition, the "Minimum" represents the total annual operating
    expenses of the Dreyfus Stock Index Fund - Initial Shares. The "Maximum"
    represents the total annual operating expenses of the ProFund VP UltraBull
    Portfolio.


EXAMPLE


This example is intended to help you compare the cost of investing in the
Contract with the cost of investing in other variable annuity contracts. These
costs include Owner transaction expenses, contract fees, separate account
annual expenses, and Fund fees and expenses for the year ended December 31,
2010.


The example assumes that you invest $10,000 in the Contract for the time
periods indicated. The example also assumes that your investment has a 5%
return each year. The example assumes the maximum contract charges and annual
expenses of any of the Fund portfolios (before expense limitations) set forth
in the previous charts. Although your actual costs may be higher or lower,
based on these assumptions, your costs would be:

1. a.  If you surrender your Contract at the end of the applicable time period
       (assuming maximum fees and expenses of any of the Fund portfolios):



       -----------------------------------------------------------
        1 YEAR          3 YEARS         5 YEARS         10 YEARS
       -----------------------------------------------------------
                                               
       $  1,004         $1,675           $2,361          $3,889
       -----------------------------------------------------------


  b.   If you surrender your Contract at the end of the applicable time period
       (assuming minimum fees and expenses of any of the Fund portfolios):




       -----------------------------------------------------------
        1 YEAR          3 YEARS         5 YEARS         10 YEARS
       -----------------------------------------------------------
                                               
       $  863           $1,254           $1,659          $2,452
       -----------------------------------------------------------



7 SUMMARY OF THE CONTRACT





2. a.  If you do not surrender your Contract (assuming maximum fees and
       expenses of any of the Fund portfolios):



       -----------------------------------------------------------
        1 YEAR          3 YEARS         5 YEARS         10 YEARS
       -----------------------------------------------------------
                                               
       $  365           $1,112           $1,878          $3,889
       -----------------------------------------------------------


   b.  If you do not surrender your Contract (assuming minimum fees and
       expenses of any of the Fund portfolios):




       -----------------------------------------------------------
        1 YEAR          3 YEARS         5 YEARS         10 YEARS
       -----------------------------------------------------------
                                               
       $  215             $664           $1,139          $2,452
       -----------------------------------------------------------



3. a.  If you annuitize your Contract and the proceeds are settled under
       Settlement Options 3 or 3A (life income with annuity options) (assuming
       maximum fees and expenses of any of the Fund portfolios):



       -----------------------------------------------------------
        1 YEAR          3 YEARS         5 YEARS         10 YEARS
       -----------------------------------------------------------
                                               
       $  1,004         $1,112           $1,878          $3,889
       -----------------------------------------------------------


  b.   If you annuitize your Contract and the proceeds are settled under
       Settlement Options 3 or 3A (life income with annuity options) (assuming
       minimum fees and expenses of any of the Fund portfolios):




       -----------------------------------------------------------
        1 YEAR          3 YEARS         5 YEARS         10 YEARS
       -----------------------------------------------------------
                                               
       $  863            $664            $1,139          $2,452
       -----------------------------------------------------------



4. a.  If you annuitize your Contract and the proceeds are settled under
       Settlement Options 1, 2 or 4 (annuity income without life contingencies)
       (assuming maximum fees and expenses of any of the Fund portfolios):



       -----------------------------------------------------------
        1 YEAR          3 YEARS         5 YEARS         10 YEARS
       -----------------------------------------------------------
                                               
       $  1,004         $1,675           $2,361          $3,889
       -----------------------------------------------------------


  b.   If you annuitize your Contract and the proceeds are settled under
       Settlement Options 1, 2 or 4 (annuity income without life contingencies)
       (assuming minimum fees and expenses of any of the Fund portfolios):




       -----------------------------------------------------------
        1 YEAR          3 YEARS         5 YEARS         10 YEARS
       -----------------------------------------------------------
                                               
       $  863           $1,254           $1,659          $2,452
       -----------------------------------------------------------



For the purposes of the Fee Tables and the Example, we assume that the Contract
is owned during the accumulation period. (See "Charges and Deductions.") On and
after the annuity starting date, different fees and charges will apply.

OTHER CONTRACTS


We offer a variety of fixed and variable annuity Contracts. They may offer
features, including investment options, fees and/or charges that are different
from those in the Contracts offered by this Prospectus. Not every Contract is
offered through the same distributor. Upon request, your registered
representative can show you information regarding other annuity Contracts that
he or she distributes. You can also contact us to find out more about any of
MONY Life Insurance Company of America annuity Contracts.


CONDENSED FINANCIAL INFORMATION


Please see Appendix I at the end of this prospectus for the unit values and the
number of units outstanding as of the end of the period shown for each of the
variable investment options available as of December 31, 2010.



                                                       SUMMARY OF THE CONTRACT 8





2. WHO IS MONY LIFE INSURANCE COMPANY OF AMERICA?



--------------------------------------------------------------------------------

MONY LIFE INSURANCE COMPANY OF AMERICA

We are MONY Life Insurance Company of America (the "Company"), an Arizona stock
life insurance corporation organized in 1969. The Company is an indirect,
wholly-owned subsidiary of AXA Financial, Inc., a holding company, which is
itself an indirect, wholly-owned subsidiary of AXA SA ("AXA"). AXA is a French
holding company for an international group of insurance and related financial
services companies. As the ultimate sole shareholder of the Company, and under
its other arrangements with the Company and parent, AXA exercises significant
influence over the operations and capital structure of the Company and its
parent. AXA holds its interest in the Company through a number of other
intermediate holding companies, including Oudinot Participations, AXA America
Holdings Inc. AXA Equitable Financial Services, LLC, and MONY Life Insurance
Company, a life insurance company. The Company is obligated to pay all amounts
that are promised to be paid under the contracts. No company other than the
Company, however, has any legal responsibility to pay amounts that the Company
owes under the contracts.


AXA Financial, Inc. and its consolidated subsidiaries managed approximately
$575.3 billion in assets as of December 31, 2010. The Company is licensed to
sell life insurance and annuities in forty-nine states (not including New
York), the District of Columbia, the U.S. Virgin Islands and Puerto Rico. Our
home office is located at 1290 Avenue of the Americas, New York, NY 10104.

HOW TO REACH US

To obtain (1) any forms you need for communicating with us, (2) unit values and
other values under your policy, and (3) any other information or materials that
we provide in connection with your Contract or the Portfolios, you may
communicate with our processing office as listed below for the purposes
described. Please refer to "Telephone/  Fax/Web Transactions" for effective
dates for processing telephone, Internet, and facsimile requests, later in this
prospectus. Certain methods of contacting us, such as by telephone or
electronically may be unavailable or delayed (for example our fax service may
not be available at all times and/or we may be unavailable due to emergency
closing). In addition, the level and type of service available may be
restricted based on criteria established by us. In order to avoid delays in
processing, please send your correspondence and check to the appropriate
location, as follows:



--------------------------------------------------------------------------------
FOR CORRESPONDENCE WITH CHECKS:
--------------------------------------------------------------------------------



FOR SUBSEQUENT CONTRIBUTIONS SENT BY REGULAR MAIL:

     MONY Life Insurance Company of America
     P.O. Box 5064
     New York, NY 10087-5064

FOR SUBSEQUENT CONTRIBUTIONS SENT BY EXPRESS DELIVERY:

     JPMorgan Chase - Lockbox Processing
     Lockbox - MONY Life Insurance Company of America - LBX 5064
     4 Chase Metrotech Center
     7th Floor East
     Brooklyn, NY 11245



--------------------------------------------------------------------------------
FOR CORRESPONDENCE WITHOUT CHECKS:
--------------------------------------------------------------------------------



FOR ALL OTHER COMMUNICATIONS (E.G., REQUESTS FOR TRANSFERS, WITHDRAWALS, OR
REQUIRED NOTICES) SENT BY MAIL:


     MONY Life Insurance Company of America
     Policyholder Services
     100 Madison Street
     Syracuse, New York 13202

Your correspondence will be picked up at the mailing address noted above and
delivered to our processing office. Your correspondence, however, is not
considered received by us until it is received at our processing office. Where
this prospectus refers to the day when we receive a contribution, request,
election, notice, transfer or any other transaction request from you, we mean
the day on which that item (or the last thing necessary for us to process that
item) arrives in complete and proper form at our processing office or via the
appropriate telephone or fax number if the item is a type we accept by those
means. There are two main exceptions: if the item arrives (1) on a day that is
not a business day or (2) after the close of a business day, then, in each
case, we are deemed to have received that item on the next business day. Our
processing office is: 100 Madison Street, Syracuse, New York 13202.

--------------------------------------------------------------------------------
BY TOLL-FREE PHONE:
--------------------------------------------------------------------------------

Customer service representatives are available weekdays from 9:00 a.m. to 5:00
p.m., Eastern Time at 1-800-487-6669.

--------------------------------------------------------------------------------
BY INTERNET:
--------------------------------------------------------------------------------

Clients may access Online Account Access by visiting our Website at
www.axa-equitable.com. Our Website provides access to account information and
customer service. After enrolling and setting up a password, you can view
account details, perform certain transactions, print customer service forms and
find answers to Frequently Asked Questions (FAQs).

You can also change your allocation percentages, transfer among investment
options, make a payment, and/or change your address (1) by toll-free phone, (2)
over the Internet, through Online Account Access, or (3) by writing our
Operations Center. For more information about the transaction requests you can
make by phone, fax or internet, see "Telephone/fax/web transactions" later in
this prospectus.


9  WHO IS MONY LIFE INSURANCE COMPANY OF AMERICA?





MONY AMERICA VARIABLE ACCOUNT A

MONY America Variable Account A is a separate investment account of the
Company. Presently, only Purchase Payments for individual flexible payment
variable annuity contracts are permitted to be allocated to MONY America
Variable Account A. The assets in MONY America Variable Account A are kept
separate from the General Account assets and other separate accounts of the
Company.

The Company owns the assets in MONY America Variable Account A. The Company is
required to keep assets in MONY America Variable Account A that equal the total
market value of the contract liabilities funded by MONY America Variable
Account A. Realized or unrealized income gains or losses of MONY America
Variable Account A are credited or charged against MONY America Variable
Account A assets without regard to the other income, gains or losses of the
Company. Reserves and other liabilities under the contracts are assets of MONY
America Variable Account A. MONY America Variable Account A assets are not
chargeable with liabilities of the Company's other businesses. The assets of
MONY America Variable Account A are, however, available to cover the
liabilities of the Company's General Account to the extent that the assets of
MONY America Variable Account A exceed the liabilities of the Contracts
supported by it. The amount of some of our obligations under the Contracts is
based on the assets in MONY America Variable Account A. However, the
obligations themselves are obligations of the Company.

MONY America Variable Account A was authorized by the Board of Directors of the
Company and established under Arizona law on March 27, 1987. MONY America
Variable Account A is registered under the Investment Company Act of 1940 (the
"1940 Act") and is registered and classified under that act as a "unit
investment trust". The SEC, however, does not manage or supervise the Company
or MONY America Variable Account A. Although MONY America Variable Account A is
registered, the Securities and Exchange Commission (the "SEC") does not monitor
the activity of MONY America Variable Account A on a daily basis. The Company
is not required to register, and is not registered, as an investment company
under the "1940 Act". A unit investment trust is a type of investment company.
For state law purposes, MONY America Variable Account A is treated as a part or
division of the Company.

MONY America Variable Account A is divided into subdivisions called
subaccounts. Each subaccount invests only in shares of a designated portfolio
of the Funds. For example, the EQ/Core Bond Index Subaccount invests solely in
shares of the EQ/Core Bond Index Portfolio of the EQ Advisors Trust. These
portfolios serve only as the underlying investment for variable annuity and
variable life insurance contracts issued through separate accounts of the
Company or other life insurance companies. The portfolios may also be available
to certain pension accounts. The portfolios are not available directly to
individual investors. In the future, we reserve the right, in compliance with
the laws that apply, to establish additional subaccounts; eliminate
subaccounts; combine any two or more subaccounts; transfer the assets we
determine to be the shares of the class of contracts to which the contracts
belong from any subaccount to another subaccount; restrict or eliminate any
voting rights as to the MONY America Variable Account A; and cause one or more
subaccounts to invest some or all of their assets in one or more other trusts
or investment companies of MONY America Variable Account A if marketing needs,
tax conditions, or investment conditions warrant. Future subaccounts may invest
in other portfolios of the Funds or in other securities, as permitted by
applicable law. Any new subaccounts may be made available to existing contracts
on a basis to be determined by us. If any of these changes are made, we may, by
appropriate endorsement, change the Contract to reflect the change.


                              WHO IS MONY LIFE INSURANCE COMPANY OF AMERICA?  10





3. THE FUNDS



--------------------------------------------------------------------------------

Each available subaccount of MONY America Variable Account A will invest only
in the shares of the Funds. We offer both affiliated and unaffiliated Funds,
which in turn offer one or more portfolios. There is a separate subaccount,
which corresponds to each portfolio of a fund offered under the Contract. AXA
Equitable Funds Management Group, LLC, a wholly owned subsidiary of AXA
Equitable, serves as the investment manager of the portfolios of AXA Premier
VIP Trust and EQ Advisors Trust. For some portfolios, AXA Equitable Funds
Management Group, LLC has entered into sub-advisory agreements with investment
advisers (the "sub-advisers") to carry out the day-to-day investment decisions
for the portfolios. As such, AXA Equitable Funds Management Group, LLC oversees
the activities of the sub-advisers with respect to the Trusts and is
responsible for retaining or discontinuing the services of those sub-advisers.
The chart below indicates the sub-adviser(s) for each portfolio, if any. The
chart below also shows the currently available portfolios and their investment
objectives.

You should be aware that AXA Advisors, LLC and AXA Distributors, LLC (together,
the "Distributors") receive 12b-1 fees from affiliated portfolios for providing
certain distribution and/or shareholder support services. These fees will not
exceed 0.25% of the portfolios' average daily net assets. The affiliated
portfolios' sub-advisers and/or their affiliates also contribute to the cost of
expenses for sales meetings or seminar sponsorships that may relate to the
policies and/or the sub-advisers' respective portfolios. It may be more
profitable for us to offer affiliated portfolios than to offer unaffiliated
portfolios.

The Funds are registered with the SEC under the 1940 Act. The Funds, or any of
them, may withdraw from sale any or all the respective portfolios as allowed by
applicable law. Not all Funds may be available in all states or in all markets.


AXA Equitable or the Distributors may directly or indirectly receive 12b-1 fees
and additional payments from certain unaffiliated portfolios, their advisers,
sub-advisers, distributors or affiliates, for providing certain administrative,
marketing, distribution and/or shareholder support services. These fees and
payments range from 0% to 0.60% of the unaffiliated portfolios' average daily
net assets. The Distributors may also receive payments from the advisers or
sub-advisers of the unaffiliated portfolios or their affiliates for certain
distribution services, including expenses for sales meetings or seminar
sponsorships that may relate to the contracts and/or the advisers' respective
portfolios.

As a contract owner, you may bear the costs of some or all of these fees and
payments through your indirect investment in the portfolios. (See the
portfolios' prospectuses for more information.) These fees and payments will
reduce the underlying portfolios' investment returns. AXA Equitable may profit
from these fees and payments.

AXA Equitable considers the availability of these fees and payment arrangements
during the selection process for the underlying portfolios. These fees and
payment arrangements may create an incentive for us to select portfolios (and
classes of shares of portfolios) that pay us higher amounts.

You should note that some portfolios have objectives and strategies that are
substantially similar to those of certain funds that are purchased directly
rather than under a variable insurance product such as the Contract. These
portfolios may even have the same manager(s) and/or a similar name. However,
there are numerous factors that can contribute to differences in performance
between two investments, particularly over short periods of time. Such factors
include fees; the timing of stock purchases and sales; differences in fund cash
flows; and specific strategies employed by the portfolio manager.

The AXA Allocation Portfolios offer contract owners a convenient opportunity to
invest in other portfolios that are managed and have been selected for
inclusion in the AXA Allocation Portfolios by AXA Equitable Life Insurance
Company ("AXA Equitable"), the investment manager of the AXA Premier VIP Trust
and EQ Advisors Trust. AXA Advisors, LLC, an affiliated broker-dealer of the
Company, may promote the benefits of such portfolios to contract owners and/or
suggest, incidental to the sale of this Contract, that contract owners consider
whether allocating some or all of their account value to such portfolios is
consistent with their desired investment objectives. In doing so, AXA
Equitable, and/or its affiliates, may be subject to conflicts of interest
insofar as AXA Equitable may derive greater revenues from the AXA Allocation
Portfolios than certain other portfolios available to you under your Contract.
Please see "Payment and allocation of Purchase Payments" in "Detailed
information about the Contract" for more information about your role in
managing your allocations.






-----------------------------------------------------------------------------------------------------------------------------------
AXA PREMIER VIP TRUST                                                                       INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                  SHARE CLASS   OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                   
AXA AGGRESSIVE ALLOCATION(1)     Class B      Seeks long-term capital appreciation.         o   AXA Equitable Funds Management
                                                                                                Group, LLC
-----------------------------------------------------------------------------------------------------------------------------------
AXA CONSERVATIVE ALLOCATION(1)   Class B      Seeks a high level of current income.         o   AXA Equitable Funds Management
                                                                                                Group, LLC
-----------------------------------------------------------------------------------------------------------------------------------
AXA CONSERVATIVE-PLUS            Class B      Seeks current income and growth of capital,   o   AXA Equitable Funds Management
 ALLOCATION(1)                                with a greater emphasis on current income.        Group, LLC
-----------------------------------------------------------------------------------------------------------------------------------
AXA MODERATE ALLOCATION(1)       Class B      Seeks long-term capital appreciation and      o   AXA Equitable Funds Management
                                              current income.                                   Group, LLC
-----------------------------------------------------------------------------------------------------------------------------------
AXA MODERATE-PLUS                Class B      Seeks long-term capital appreciation and      o   AXA Equitable Funds Management
 ALLOCATION(1)                                current income, with a greater emphasis on        Group, LLC
                                              capital appreciation.
-----------------------------------------------------------------------------------------------------------------------------------



11 THE FUNDS









-----------------------------------------------------------------------------------------------------------------------------------
AXA PREMIER VIP TRUST                                                                       INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                  SHARE CLASS   OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                   
MULTIMANAGER SMALL CAP           Class B      Seeks long-term growth of capital.            o   AXA Equitable Funds Management
 GROWTH                                                                                         Group, LLC
                                                                                            o   BlackRock Investment Management, LLC
                                                                                            o   Morgan Stanley Investment
                                                                                                Management Inc.
                                                                                            o   NorthPointe Capital, LLC
                                                                                            o   Wells Capital Management Inc.
-----------------------------------------------------------------------------------------------------------------------------------






-----------------------------------------------------------------------------------------------------------------------------------
EQ ADVISORS TRUST                                                                           INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                  SHARE CLASS   OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                   
ALL ASSET ALLOCATION            Class IB      Seeks long-term capital appreciation and      o   AXA Equitable Funds Management
                                              current income.                                   Group, LLC
-----------------------------------------------------------------------------------------------------------------------------------
EQ/BLACKROCK BASIC VALUE        Class IB      Seeks to achieve capital appreciation and     o   BlackRock Investment Management, LLC
 EQUITY                                       secondarily, income.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/BOSTON ADVISORS EQUITY       Class IB      Seeks a combination of growth and income      o   Boston Advisors, LLC
 INCOME                                       to achieve an above-average and consistent
                                              total return.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/CALVERT SOCIALLY             Class IA      Seeks to achieve long-term capital apprecia-  o   Bridgeway Capital Management, Inc.
 RESPONSIBLE                                  tion.                                         o   Calvert Investment Management
                                                                                                Company, Inc.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/CAPITAL GUARDIAN RESEARCH    Class IA      Seeks to achieve long-term growth of capital. o   Capital Guardian Trust Company
-----------------------------------------------------------------------------------------------------------------------------------
EQ/CORE BOND INDEX              Class IA      Seeks to achieve a total return before        o   SSgA Funds Management, Inc.
                                              expenses that approximates the total return
                                              performance of the Barclays Capital Interme-
                                              diate U.S. Government/Credit Index,
                                              including reinvestment of dividends, at a
                                              risk level consistent with that of the
                                              Barclays Capital Intermediate U.S.
                                              Government/Credit Index.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/EQUITY GROWTH PLUS           Class IB      Seeks to achieve long-term growth of capital. o   AXA Equitable Funds Management
                                                                                                Group, LLC
                                                                                            o   BlackRock Capital Management, Inc.
                                                                                            o   BlackRock Investment Management, LLC
-----------------------------------------------------------------------------------------------------------------------------------
EQ/GAMCO MERGERS AND            Class IB      Seeks to achieve capital appreciation.        o   GAMCO Asset Management, Inc.
 ACQUISITIONS
-----------------------------------------------------------------------------------------------------------------------------------
EQ/GAMCO SMALL COMPANY          Class IB      Seeks to maximize capital appreciation.       o   GAMCO Asset Management, Inc.
 VALUE
-----------------------------------------------------------------------------------------------------------------------------------
EQ/INTERMEDIATE GOVERNMENT      Class IA      Seeks to achieve a total return before        o   SSgA Funds Management, Inc.
 BOND INDEX                                   expenses that approximates the total return
                                              performance of the Barclays Capital Interme-
                                              diate U.S. Government Bond Index, including
                                              reinvestment of dividends, at a risk level
                                              consistent with that of the Barclays Capital
                                              Intermediate U.S. Government Bond Index.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/LARGE CAP VALUE INDEX(2)     Class IA      Seeks to achieve a total return before        o   SSgA Funds Management, Inc.
                                              expenses that approximates the total return
                                              performance of the Russell 1000 Value
                                              Index, including reinvestment of dividends,
                                              at a risk level consistent with that of the
                                              Russell 1000 Value Index.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/LORD ABBETT GROWTH AND       Class IA      Seeks to achieve capital appreciation and     o   Lord, Abbett & Co. LLC
 INCOME(3)                                    growth of income without excessive fluctua-
                                              tion in market value.
-----------------------------------------------------------------------------------------------------------------------------------



                                                                   THE FUNDS 12










-----------------------------------------------------------------------------------------------------------------------------------
EQ ADVISORS TRUST                                                                           INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                  SHARE CLASS   OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                      
EQ/MFS INTERNATIONAL GROWTH(4)  Class IB      Seeks to achieve capital appreciation.        o   MFS Investment Management
-----------------------------------------------------------------------------------------------------------------------------------
EQ/MID CAP INDEX                Class IA      Seeks to achieve a total return before        o   SSgA Funds Management, Inc.
                                              expenses that approximates the total
                                              return performance of the S&P Mid Cap
                                              400 Index, including reinvestment of
                                              dividends, at a risk level consistent
                                              with that of the S&P Mid Cap 400 Index.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/MID CAP VALUE PLUS           Class IA      Seeks to achieve long-term capital            o   AXA Equitable Funds Management
                                              appreciation.                                     Group, LLC
                                                                                            o   BlackRock Investment Management, LLC
                                                                                            o   Wellington Management Company, LLP
-----------------------------------------------------------------------------------------------------------------------------------
EQ/MONEY MARKET                 Class IA      Seeks to obtain a high level of current       o   The Dreyfus Corporation
                                              income, preserve its assets and maintain
                                              liquidity.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/MONTAG & CALDWELL            Class IA      Seeks to achieve capital appreciation.        o   Montag & Caldwell, LLC
 GROWTH
-----------------------------------------------------------------------------------------------------------------------------------
EQ/MORGAN STANLEY MID CAP       Class IA      Seeks to achieve capital growth.              o   Morgan Stanley Investment Manage-
 GROWTH                                                                                         ment Inc.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/PIMCO ULTRA SHORT BOND       Class IA      Seeks to generate a return in excess of       o   Pacific Investment Management
                                              traditional money market products while           Company, LLC
                                              maintaining an emphasis on preservation of
                                              capital and liquidity.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/QUALITY BOND PLUS            Class IA      Seeks to achieve high current income          o   AllianceBernstein L.P.
                                              consistent with moderate risk to capital.     o   AXA Equitable Funds Management
                                                                                                Group, LLC
-----------------------------------------------------------------------------------------------------------------------------------
EQ/T. ROWE PRICE GROWTH STOCK   Class IA      Seeks to achieve long-term capital            o   T. Rowe Price Associates, Inc.
                                              appreciation and secondarily, income.
-----------------------------------------------------------------------------------------------------------------------------------
EQ/UBS GROWTH AND INCOME        Class IA      Seeks to achieve total return through         o   UBS Global Asset Management
                                              capital appreciation with income as               (Americas) Inc.
                                              a secondary consideration.
-----------------------------------------------------------------------------------------------------------------------------------







-----------------------------------------------------------------------------------------------------------------------------------
DREYFUS STOCK INDEX FUND, INC. -                                                            INVESTMENT MANAGER (OR SUB-ADVISER(S),
INITIAL SHARES                                OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                      
DREYFUS STOCK INDEX FUND, INC.                The fund seeks to match the total return of   o   The Dreyfus Corporation
                                              the Standard & Poor's 500 Composite Stock
                                              Price Index.
-----------------------------------------------------------------------------------------------------------------------------------






-----------------------------------------------------------------------------------------------------------------------------------
FIDELITY(R) VARIABLE INSURANCE                                                              INVESTMENT MANAGER (OR SUB-ADVISER(S),
PRODUCTS (VIP) - SERVICE CLASS                OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                      
FIDELITY(R) VIP CONTRAFUND(R)                 Seeks long-term capital appreciation.         o   Fidelity Management and Research
 PORTFOLIO                                                                                      Company (FMR)
-----------------------------------------------------------------------------------------------------------------------------------






-----------------------------------------------------------------------------------------------------------------------------------
FRANKLIN TEMPLETON VARIABLE
INSURANCE PRODUCTS TRUST -                                                                  INVESTMENT MANAGER (OR SUB-ADVISER(S),
CLASS 2 PORTFOLIO NAME                        OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                      
FRANKLIN INCOME SECURITIES                    The Fund's investment goal is to maximize     o   Franklin Advisers, Inc.
 FUND                                         income while maintaining prospects for
                                              capital appreciation.
-----------------------------------------------------------------------------------------------------------------------------------
FRANKLIN RISING DIVIDENDS                     Seeks long-term capital appreciation, with    o   Franklin Advisory Services, LLC
 SECURITIES FUND                              preservation of capital as an important
                                              consideration.
-----------------------------------------------------------------------------------------------------------------------------------






-----------------------------------------------------------------------------------------------------------------------------------
JANUS ASPEN SERIES -                                                                        INVESTMENT MANAGER (OR SUB-ADVISER(S),
INSTITUTIONAL SHARES                          OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                      
BALANCED PORTFOLIO                            Seeks long-term capital growth, consistent    o   Janus Capital Management LLC
                                              with preservation of capital and balanced by
                                              current income.
-----------------------------------------------------------------------------------------------------------------------------------
ENTERPRISE PORTFOLIO                          Seeks long-term growth of capital.            o   Janus Capital Management LLC
-----------------------------------------------------------------------------------------------------------------------------------



13 THE FUNDS









-----------------------------------------------------------------------------------------------------------------------------------
JANUS ASPEN SERIES -                                                                        INVESTMENT MANAGER (OR SUB-ADVISER(S),
INSTITUTIONAL SHARES                          OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                      
FORTY PORTFOLIO(5)                            Seeks long-term growth of capital.            o    Janus Capital Management LLC
-----------------------------------------------------------------------------------------------------------------------------------
WORLDWIDE PORTFOLIO                           Seeks long-term growth of capital.(6)         o    Janus Capital Management LLC
-----------------------------------------------------------------------------------------------------------------------------------






-----------------------------------------------------------------------------------------------------------------------------------
OPPENHEIMER VARIABLE ACCOUNT                                                                INVESTMENT MANAGER (OR SUB-ADVISER(S),
FUNDS - SERVICE CLASS                         OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                      
OPPENHEIMER GLOBAL                            Seeks long-term capital appreciation by       o    OppenheimerFunds, Inc.
 SECURITIES FUND/VA                           investing a substantial portion of its
                                              assets in securities of foreign issuers,
                                              "growth-type" companies, cyclical
                                              industries and special situations that are
                                              considered to have appreciation
                                              possibilities.
-----------------------------------------------------------------------------------------------------------------------------------






-----------------------------------------------------------------------------------------------------------------------------------
PIMCO VARIABLE INSURANCE TRUST -                                                            INVESTMENT MANAGER (OR SUB-ADVISER(S),
ADMINISTRATIVE CLASS                          OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                      
GLOBAL BOND PORTFOLIO                         Seeks to maximize total return, consistent    o    Pacific Investment Management
 (UNHEDGED)                                   with preservation of capital and prudent           Company, LLC
                                              investment management.
-----------------------------------------------------------------------------------------------------------------------------------






-----------------------------------------------------------------------------------------------------------------------------------
PROFUNDS VP                                                                                 INVESTMENT MANAGER (OR SUB-ADVISER(S),
PORTFOLIO NAME                                OBJECTIVE                                     AS APPLICABLE)
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                      
PROFUND VP BEAR                               Seeks daily investment results, before fees   o    ProFund Advisors, LLC
                                              and expenses, that correspond to the inverse
                                              (opposite) of the daily performance of the
                                              S&P 500 Index.
-----------------------------------------------------------------------------------------------------------------------------------
PROFUND VP RISING RATES                       Seeks daily investment results, before fees   o    ProFund Advisors, LLC
 OPPORTUNITY                                  and expenses, that correspond to the one
                                              and one-quarter times (125%) the inverse
                                              (opposite) of the daily price movement of
                                              the most recently issued 30-year U.S.
                                              Treasury Bond ("Long Bond").
-----------------------------------------------------------------------------------------------------------------------------------
PROFUND VP ULTRABULL                          Seeks daily investment results, before fees   o    ProFund Advisors, LLC
                                              and expenses that correspond to twice
                                              (200%) the daily performance of the S&P
                                              500 Index.
-----------------------------------------------------------------------------------------------------------------------------------




(1) The "AXA Allocation" portfolios.
(2) This Portfolio will become available on or about May 20, 2011.
(3) Effective on or about May 20, 2011, subject to regulatory and shareholder
    approvals, interests in the EQ/Large Cap Value Index (the "surviving
    option") will replace interests in the EQ/Lord Abbett Growth and Income (the
    "replaced" option). We will move the assets from the replaced option into
    the surviving option on the date of the scheduled merger. The value of your
    interest in the surviving option will be the same as it was in the replaced
    option. We will also automatically direct any contributions made to a
    replaced option to the surviving option. Any allocation election to a
    replaced option will be considered as an allocation election to the
    surviving option.
(4) This is the Portfolio's new name, effective on or about May 20, 2011,
    subject to regulatory approval. The Portfolio's former name was
    EQ/International Growth.
(5) Unlike the other Funds, the Janus Aspen Forty Portfolio is a nondiversified,
    open-end management investment company. A nondiversified Fund may hold a
    larger position in a smaller number of securities than a diversified Fund.
    This means that a single security's increase or decrease in value may have a
    greater impact on the return and net asset value of a nondiversified Fund
    than a diversified Fund.
(6) This is the Portfolio's new investment objective effective May 16, 2011. See
    the Trust's Prospectus for information regarding its investment objective
    prior to May 16, 2011.


YOU SHOULD CONSIDER THE INVESTMENT OBJECTIVES, RISKS AND CHARGES AND EXPENSES
OF THE PORTFOLIOS CAREFULLY BEFORE INVESTING. SHARE CLASSES, WHERE APPLICABLE,
ARE DEFINED IN THE CORRESPONDING FUND PROSPECTUS. THE PROSPECTUSES FOR THE FUND
CONTAIN THIS AND OTHER IMPORTANT INFORMATION ABOUT THE PORTFOLIOS. THE
PROSPECTUSES SHOULD BE READ CAREFULLY BEFORE INVESTING. IN ORDER TO OBTAIN
COPIES OF FUND PROSPECTUSES THAT DO NOT ACCOMPANY THIS PROSPECTUS, YOU MAY CALL
ONE OF OUR CUSTOMER SERVICE REPRESENTATIVES AT 1-800-487-6669.

Each Owner should periodically review their allocation of Purchase Payments and
Fund Value among the subaccounts and the Guaranteed Interest Account with
Market Value Adjustment in light of their current objectives, the current
market conditions, and the risks of investing in each of the Funds' various
portfolios. A full description of the objectives, policies, restrictions, risks
and expenses for each of the Funds' portfolios can be found in the prospectus
for each of the Funds.


PURCHASE OF PORTFOLIO SHARES BY MONY AMERICA VARIABLE ACCOUNT A


MONY America Variable Account A will buy and redeem shares from the Funds at
net asset value. Shares will be redeemed when needed for the Company to:

o   collect charges under the Contracts;

o   pay Cash Value on full surrenders of the Contract;

o   fund partial surrenders;

o   provide benefits under the Contracts; and

                                                                    THE FUNDS 14





o   transfer assets from one subaccount to another or between one or more
    subaccounts of MONY America Variable Account A and the Guaranteed Interest
    Account with Market Value Adjustment as requested by Owners.

Any dividend or capital gain distribution received from a portfolio of a Fund
will be:

o   reinvested immediately at net asset value in shares of that portfolio; and

o   kept as assets of the corresponding subaccount.
--------------------------------------------------------------------------------
CASH VALUE -- The Contract's Fund Value, less (1) any applicable surrender
charge, (2) any outstanding debt, and (3) any applicable market value
adjustment.
--------------------------------------------------------------------------------
Shares of the Funds are not sold directly to the general public. They are sold
to the Company, and may be sold to other insurance companies that issue
variable annuity and variable life insurance contracts. In addition, they may
be sold to retirement plans.

When a Fund sells shares in any of its portfolios both to variable annuity and
to variable life insurance company separate accounts, it engages in mixed
funding. When a Fund sells shares in any of its portfolios to separate accounts
of unaffiliated life insurance companies, it engages in shared funding. Each
Fund may engage in mixed and shared funding. Therefore, due to differences in
redemption rates or tax treatment, or other considerations, the interests of
various shareholders participating in a Fund could conflict.

The Board of Directors or Trustees of each of the Funds monitors the respective
Fund for the existence of material irreconcilable conflict between the
interests of variable annuity Owners and variable life insurance Owners. The
Boards shall report any such conflict to the boards of the Company and its
affiliates. The Boards of Directors of the Company and its affiliates have
agreed to be responsible for reporting any potential or existing mixed and
shared funding conflicts to the Directors and Trustees of each of the relevant
Funds. The Boards of Directors of the Company and its affiliates will remedy
any conflict at their own cost. The remedy may include establishing a new
registered management investment company and segregating the assets underlying
the variable annuity contracts and the variable life insurance contracts.

The investment objectives and policies of certain portfolios are similar to the
investment objectives and policies of other portfolios that may be managed by
the same investment adviser or manager. The investment results of the
portfolios, however, may be higher or lower than the results of such other
portfolios. There can be no assurance, and no representation is made that the
investment results of any of the portfolios will be comparable to the
investment results of any other portfolio, even if the other portfolio has the
same investment adviser or manager, or if the other portfolio has a similar
name.


15  THE FUNDS





4. DETAILED INFORMATION ABOUT THE CONTRACT



--------------------------------------------------------------------------------


The Fund Value in MONY America Variable Account A and in the Guaranteed
Interest Account with Market Value Adjustment provide many of the benefits of
your Contract. The information in this section describes the benefits,
features, charges and major provisions of the Contract and the extent to which
those depend upon the Fund Value, particularly the Fund Value in MONY America
Variable Account A. There may be differences in your Contract, such as
differences in fees, charges and benefits because of the state where we issued
your Contract. We will include any such differences in your Contract.

PAYMENT AND ALLOCATION OF PURCHASE PAYMENTS

ISSUANCE OF THE CONTRACT


Disclosure regarding contract issuance and minimum initial Purchase Payments is
for informational purposes only. This Contract is no longer available to new
purchasers.

The Contract is between you and the Company. The Contract is not an investment
advisory account, and the Company is not providing any investment advice or
managing the allocations under your Contract. In the absence of a specific
written arrangement to the contrary, you as the owner of the Contract, have the
sole authority to make investment allocations and other decisions under the
Contract. Your AXA Advisors' financial professional is acting as a
broker-dealer registered representative, and is not authorized to act as an
investment advisor or to manage the allocations under your Contract. If your
financial professional is a registered representative with a broker-dealer
other than AXA Advisors, you should speak with him/her regarding any different
arrangements that may apply.

Individuals who want to buy a Contract must:

(1)    Complete an application;


(2)    Personally deliver the application to;


     (a)   a licensed agent of the Company who is also a registered
           representative of AXA Advisors, LLC or AXA Distributors, LLC
           (together, the "Distributors") who act as the principal underwriters
           for the Contracts, or

     (b)   a licensed agent who is also a registered representative of a
           broker dealer which had been authorized by the Distributors to sell
           the Contract; and

(3)    Pay the minimum initial Purchase Payment.

If we receive a completed application and all other information necessary for
processing a purchase order at our Operations Center, we will apply your
initial Purchase Payment no later than two Business Days after we receive the
order. While attempting to finish an incomplete application, we may hold your
initial Purchase Payment for no more than five Business Days. If an incomplete
application cannot be completed within those five days, we will inform you of
the reasons, and will return your Purchase Payment immediately (unless you
specifically authorize us to keep it until the application is complete). Once
you complete your application, we must apply the initial Purchase Payment
within two Business Days. We will apply any additional Purchase Payments you
make on the Business Day we receive them at our Operations Center.

The Contract may be used with certain tax qualified plans. The Contract
includes attributes such as tax deferral on accumulated earnings. Qualified
retirement plans provide their own tax deferral benefit; the purchase of this
Contract does not provide additional tax deferral benefits beyond those
provided in the Qualified Plan. Accordingly, if you are purchasing this
Contract, you should purchase it for its death benefit, annuity benefits, and
other non-tax related benefits. Please consult a tax adviser for information
specific to your circumstances in order to determine whether the Contract is an
appropriate investment for you.

The minimum initial Purchase Payment for individuals varies depending upon the
use of the Contract and the method of purchase. The chart below shows the
minimum initial Purchase Payment for each situation.


                                     DETAILED INFORMATION ABOUT THE CONTRACT  16








----------------------------------------------------------------------------------------------------------------------------------
USE OF CONTRACT OR METHOD OF MAKING PURCHASE PAYMENT                          MINIMUM INITIAL PURCHASE PAYMENT
----------------------------------------------------------------------------------------------------------------------------------
                                                                           
Individual retirement accounts and annuities under Section 408 of the         $2,000
Code (other than Simplified Employee Pensions), including Roth IRAs
under Section 408A of the Code
----------------------------------------------------------------------------------------------------------------------------------
Non-Qualified Contracts                                                       $2,000
----------------------------------------------------------------------------------------------------------------------------------
H.R. 10 plans (self-employed individuals' retirement plans under Section      $  600
401 of the Code), certain corporate or association retirement plans, and
Simplified Employee Pensions under Section 408 of the Code
----------------------------------------------------------------------------------------------------------------------------------
Annuity purchase plans sponsored by certain tax-exempt organizations,         $  600
governmental entities and deferred compensation plans under Section
457 of the Code
----------------------------------------------------------------------------------------------------------------------------------
Payroll deduction and automatic checking account withdrawal plans             Annualized rate of $600 (i.e., $600 per year, $300
                                                                              semiannually, $150 quarterly or $50 per month)
----------------------------------------------------------------------------------------------------------------------------------
Government Allotment Plans                                                    $50 per month
----------------------------------------------------------------------------------------------------------------------------------


--------------------------------------------------------------------------------
GOVERNMENT ALLOTMENT PLANS -- Payroll deduction plans used for financial
products by government employees.
--------------------------------------------------------------------------------
Additional Purchase Payments may be made at any time before the Annuity
starting date as long as the Annuitant is living. However, for certain
automatic payment plans, the smallest additional payment is $50. The Company
reserves the right to revise its rules from time to time to specify different
minimum Purchase Payments for such plans. In addition, the prior approval of
the Company is needed before it will accept a Purchase Payment if, with that
Payment, that would cause Cumulative Purchase Payments, less any partial
surrenders and their surrender charges and market value adjustment, to exceed
$1,500,000.

The Company reserves the right to reject an application for any reason
permitted by law.

Net Purchase Payments received before the Effective Date will be held in the
Company's General Account and will be credited with interest at not less than
3.50% per year if:

(1)    the Contract is issued by the Company, and

(2)    the Contract is delivered to the Owner.

No interest will be paid if the Contract is not issued or if it is declined by
the Owner.

These amounts will be held in the General Account pending end of the right to
return contract period. (See below.)
--------------------------------------------------------------------------------
EFFECTIVE DATE -- The date the contract begins as shown in the Contract.
--------------------------------------------------------------------------------

TAX-FREE "SECTION 1035" EXCHANGES

This information is no longer applicable to the purchase of these Contracts as
these Contracts are no longer available to new purchasers.

The Owner can generally exchange one annuity contract for another in a
"tax-free exchange" under Section 1035 of the Internal Revenue Code. Similar
rules may apply to changing the funding vehicle in a Qualified Plan. Before
making the exchange, the Owner should compare both contracts carefully.
Remember that if you exchange another contract for the one described in this
prospectus, you might have to pay a surrender charge on the old contract. There
will be a new surrender charge period for this Contract and other charges may
be higher (or lower) and the benefits may be different. If the exchange does
not qualify for Section 1035 treatment, the Owner may have to pay federal
income tax, and penalty taxes on the exchange. The Owner should not exchange
another contract for this one unless he or she determines, after knowing all
the facts, that the exchange is in the Owner's best interest and not just
better for the person trying to sell the Owner this Contract (that person will
generally earn a commission if the Owner buys this Contract through an exchange
or otherwise).

RIGHT TO RETURN CONTRACT PROVISION

This information is no longer applicable, as these contracts are no longer
available to new purchasers.

The Owner may return the Contract during the right to return contract period
(usually within 10 days of the delivery date). The Contract must be returned to
the Company or any agent of the Company. When the Company receives the
Contract, it will be voided as if it were never in effect. The amount to be
refunded is equal to the Purchase Payments received by the Company less any
partial surrender you made. During the right to return contract period,
Purchase Payments will be retained in the Company's General Account and will
earn interest at a rate not less than 3.50% per year. If you have not returned
the Contract at the end of the right to return contract period, we transfer the
Net Purchase Payments with interest to the subaccounts and/or the Guaranteed
Interest Account.

For contracts issued in the State of Washington, an additional 10% penalty will
be added to any Purchase Payment refund due that is not paid within 30 days of
return of the Contract to the Company. For contracts issued in the State of
Oklahoma, if payment is delayed more than 30 days, the Company will pay
interest on the proceeds at a rate required by Oklahoma law.

ALLOCATION OF PURCHASE PAYMENTS AND FUND VALUE

ALLOCATION OF PAYMENTS.  On the application, the Owner may allocate Net
Purchase Payments to any of the available subaccounts of MONY America Variable
Account A or to the Guaranteed Interest Account with Market Value Adjustment.
Net Purchase Payments (and any interest thereon) are held in the General
Account if they are received before the end of the right to return contract
period. The Net Purchase Payments will earn interest at a rate not less than
3.50% per year beginning on the later of:

(1)    the Effective Date of the Contract, or

(2)    the date the Payment is received at the Company's Operations Center.



17  DETAILED INFORMATION ABOUT THE CONTRACT






Net Purchase Payments will continue to earn 3.50% annual interest until the
right to return contract period expires. (See "Right to return contract
provision" above.) After the right to return contract period has expired, the
Contract's Fund Value will automatically be transferred to MONY America
Variable Account A subaccount(s) or to the Guaranteed Interest Account with
Market Value Adjustment according to the Owner's allocation instructions.

After the right to return contract period ends, under a non-automatic payment
plan, if the Owner does not:

(1)    specify the amount to be allocated among subaccounts, or

(2)    specify the percentage to be allocated among subaccounts, or

(3)    the amount or percentage specified is incorrect or incomplete,

the Net Purchase Payments will be allocated under the Owner's most recent
instructions on record with the Company. The percentage specified must not be
less than 10% of the Net Purchase Payment. For automatic payment plans, Net
Purchase Payments will be allocated according to the Owner's most recent
instructions on record.

The Owner may change the specified allocation formula for future Net Purchase
Payments at any time without charge by sending written notification to the
Company at the Operations Center. Prior allocation instructions may also be
changed by telephone, facsimile or via the Web subject to the rules of the
Company and its right to terminate or modify telephone, facsimile or via the
Web allocation. The Company reserves the right to deny any telephone, facsimile
or via the Web allocation request. (See "Telephone/fax/web transactions.") Any
such change, whether made in writing or by telephone, facsimile or via the Web,
will be effective within 7 days of the date we receive notice of the change.

Net Purchase Payments may be allocated in whole percentages to any of the
available subaccounts and to the Guaranteed Interest Account. Allocations must
be in whole percentages, and no allocation may be for less than 10% of a Net
Purchase Payment. Allocation percentages must total 100%. Contracts issued in
the states of Maryland, New Jersey, Oklahoma, Oregon, South Carolina, Texas and
Washington and the Commonwealths of Massachusetts and Pennsylvania must
maintain a minimum fund value balance of $2,500 in the Guaranteed Interest
Account when an allocation to said account is chosen.

CALCULATING UNIT VALUES FOR EACH SUBACCOUNT

When allocated Purchase Payments are received they are credited to subaccounts
of MONY America Variable Account A in the form of units. The number of units is
determined by dividing the dollar amount allocated to a particular subaccount
by the unit value for that subaccount for the Business Day on which the
Purchase Payment is received.

To determine the unit value of a subaccount on each Business Day, the Company
takes the prior Business Day's unit value and multiplies it by the Net
Investment Factor for the current Business Day. The Net Investment Factor is
used to measure the investment performance of a subaccount from one Business
Day to the next. The Net Investment Factor for each subaccount equals:

(1)  the net asset value per share of each Fund held in the subaccount at the
     end of the current Business Day divided by

(2)  the net asset value per share of each Fund held in the subaccount at the
     end of the prior Business day, minus

(3)  the daily mortality and expense risk charge and any other applicable
     charges adjusted for the number of calendar days in the period.

The unit value of these subaccounts may increase, decrease or remain the same
from Business Day to Business Day. The unit value depends on the investment
performance of the portfolio of the Fund in which the subaccount invests and
any expenses and charges deducted from MONY America Variable Account A. The
Owner bears the entire investment risk. Owners should periodically review their
allocations of payments and values in light of market conditions and overall
financial planning requirements.
CALCULATION OF GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT FUND
VALUE

Net Purchase Payments to be allocated to the Guaranteed Interest Account with
Market Value Adjustment will be credited to the Accumulation Period chosen by
the Owner on:

(1)  the date received at the Operations Center, or

(2)  if the day Net Purchase Payments are received is not a Business Day,
     then on the next Business Day.

Interest will be credited daily.
CALCULATION OF FUND VALUE

The Contract's Fund Value will reflect:

o   The investment performance of the selected subaccount(s) of MONY America
    Variable Account A;

o   Amounts credited (including interest) to the Guaranteed Interest Account
    with Market Value Adjustment;

o   Any amount in the loan account;

o   Any Net Purchase Payments;

o   Any transfer charges;

o   Any partial surrenders; and

o   All contract charges (including surrender charges and market value
    adjustments) imposed.

There is no guaranteed minimum Fund Value, except to the extent Net Purchase
Payments have been allocated to the Guaranteed Interest Account with Market
Value Adjustment. Because a Contract's Fund Value at any future date will be
dependent on a number of variables, it cannot be predetermined.

The Fund Value will be computed first on the Effective Date and thereafter on
each Business Day. On the Effective Date, the Contract's Fund Value will be the
Net Purchase Payments received plus any interest credited on those Payments
during the period when Net Purchase Payments are held in the General Account.
(See "Issuance of the Contract.")

After amounts allocated to the subaccounts are transferred from the General
Account to MONY America Variable Account A, on each Business Day, the
Contract's Fund Value will be computed as follows:

(1)  Determine the aggregate of the Fund Values attributable to the Contract
     in each of the subaccounts on that Business Day. This is done by
     multiplying the subaccount's unit value on that date by the number of
     subaccount units allocated to the Contract. The computation of the
     Contract's Fund Value in the subaccount is done before any other Contract
     transactions on that Business Day.



                                     DETAILED INFORMATION ABOUT THE CONTRACT  18






(2)  Add any amount credited to the Guaranteed Interest Account with Market
     Value Adjustment before that Business Day. This amount is the aggregate of
     all Net Purchase Payments allocated to the Guaranteed Interest Account with
     Market Value Adjustment and:

     o   The addition of any interest credited.

     o   Addition or subtraction of any amounts transferred.

     o   Subtraction of any partial surrenders.

     o   Subtraction of any contract charges, surrender charges, transfer
         charges, and any Market Value Adjustments

(3)  Add the value held in the loan account to secure contract loans and
     interest credited on that day on that amount;

(4)  Add any Net Purchase Payment received on that Business Day;

(5)  Subtract any partial surrender amount (reflecting any surrender charge and
     Market Value Adjustment) made on that Business Day;

(6)  Subtract any annual contract charge and/or transfer charge deductible on
     that Business Day.

Regarding (1) above, for each subaccount we multiply the number of units
credited to that subaccount by its unit value on that Business Day. The
multiplication is done BEFORE the purchase or redemption of any units on that
Business Day.

If a transaction would ordinarily require that the Contract's Fund Value be
computed for a day that is not a Business Day, the next following Business Day
will be used.

TRANSFERS.  You may transfer the value of the Contract among the subaccounts
after the right to return contract period has expired by sending a proper
written request to the Company's Operations Center. Transfers may be made by
telephone, facsimile or via the web if you have proper authorization. (See
"Telephone/fax/web transactions.") Transfers from a subaccount will be executed
at the net asset value next calculated by the Company if the transfer
instruction is received and acknowledged by 4:00 p.m., Eastern Time on a day on
which the New York Stock Exchange is open for business. If the New York Stock
Exchange is not open for business on the day of receipt, the transfer
instruction will be executed at the net asset value calculated at the close of
business on the first day thereafter on which the New York Stock Exchange is
open for business. Such transfers are subject to the Company's rules and
conditions for such privilege. Currently, there are no limitations on the
number of transfers between subaccounts. Our current transfer restrictions are
set forth in the "Disruptive transfer activity" section below.

Transfers among, to and from subaccounts may be postponed for any period during
which:

(1)  the New York Stock Exchange is closed other than customary weekend and
     holiday closings, or

(2)  trading on the New York Stock Exchange is restricted as determined by the
     Securities and Exchange Commission, or

(3)  an emergency exists as a result of which disposal of securities held by the
     Fund is not reasonably practicable or it is not reasonably practicable to
     determine the value of the net assets of the Fund.

A transfer charge is not currently imposed on transfers. (See "Charges against
fund value -- Transfer charge.") However, the Company reserves the right to
impose a charge which will not exceed $25 per transfer (except for contracts
issued in the states of South Carolina and Texas where it will not exceed $10).
If imposed the charge will be deducted from the first subaccount(s) or the
Guaranteed Interest Account with Market Value Adjustment Accumulation Period
you designate funds to be transferred from. This charge is in addition to the
amount transferred. All transfers in a single request are treated as one
transfer transaction. A transfer resulting from the first reallocation of Fund
Value at the end of the right to return contract period and transfers made at
the end of an Accumulation Period of amounts allocated to the Guaranteed
Interest Account with Market Value Adjustment (see below) will not be subject
to a transfer charge. Under present law, transfers are not taxable
transactions.
--------------------------------------------------------------------------------
EFFECTIVE DATE -- The date shown as the Effective Date of the Contract.
--------------------------------------------------------------------------------
TRANSFERS INVOLVING THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE
ADJUSTMENT. Transfers may be made from the Guaranteed Interest Account with
Market Value Adjustment at any time, but, if they are made before the end of the
3, 5, 7, or 10 year accumulation period there will be a market value adjustment
for contracts issued in most states. If the transfer request is received within
30 days before the end of the Accumulation Period, no market value adjustment
will apply.

Contracts issued in Maryland, New Jersey, Oklahoma, South Carolina, Texas and
Washington and the Commonwealths of Massachusetts and Pennsylvania, to the
extent the Owner allocates investments to the Guaranteed Interest Account, must
maintain a minimum Fund Value in the Guaranteed Interest Account of $2,500.

Please see "Payment and allocation of Purchase Payments" earlier in this
section for more information about your role in managing your allocations.

PORTFOLIO REBALANCING

Our portfolio rebalancing program can help prevent a well-conceived investment
strategy from becoming diluted over time. Investment performance will likely
cause the allocation percentages you originally selected to shift. With this
program, you may instruct us to periodically reallocate values in your
Contract. The program does not guarantee an investment gain or protect against
an investment loss. You may elect or terminate the rebalancing program at any
time. You may also change your allocations under the program at any time.
Requesting a transfer while enrolled in our rebalancing program will
automatically terminate your participation in the program. This means that your
account will no longer be rebalanced on a periodic basis. You must provide us
with written instructions if you wish your account to be rebalanced in the
future.


TELEPHONE/FAX/WEB TRANSACTIONS

Prior allocation instructions may be changed or transfers requested by
telephone, fax or via the web subject to the Company's guidelines (which we
believe to be reasonable) and the Company's right to modify or terminate the
telephone/fax/web privilege. The Company reserves the right to deny any
telephone, fax or web request.

If all telephone lines are busy or the internet is not available (for example,
during periods of substantial market fluctuations), Owners may be unable to
request telephone, fax or web allocation changes or transfers by telephone, fax
or web. In such cases, an Owner would submit a written request.


19  DETAILED INFORMATION ABOUT THE CONTRACT





We have adopted guidelines relating to changes of allocations and transfers by
telephone, fax or the web which, among other things, outlines procedures
designed to prevent unauthorized instructions. If the Owner does not follow
these procedures:

(1)  the Company shall not be liable for any loss as a result of following
     fraudulent telephone, fax or web instructions; and

(2)  the Owner will, therefore, bear the entire risk of loss due to fraudulent
     telephone, fax or web instructions.

A copy of the guidelines and our form for electing telephone/facsimile transfer
privileges is available from your financial professional or by calling us at
1-800-487-6669, Monday through Friday, 9 a.m. to 5 p.m., Eastern Time. Web
transfer privileges and a copy of the guidelines and forms are available online
at www.axaonline.com. The telephone or fax allocation and transfer privileges
may also be elected by completing the telephone or fax authorization. The
Company's form or a Contract application with a completed telephone or fax
authorization must be signed and received at the Company's Operations Center
before telephone or fax allocation instructions will be accepted. To elect web
allocation and transfer privileges, you must log on to www.axaonline.com, and
register for online account access. This online application must be
electronically signed and received by the Company via the internet before web
transaction instructions will be accepted.


SPECIAL NOTE ON RELIABILITY.  Please note that the internet and our telephone
system may not always be available. Any system, whether it is yours, your
service provider's, or your registered representative's, can experience
unscheduled outages or slowdowns for a variety of reasons. These outages or
slowdowns may delay or prevent our processing of your request. Although we have
taken precautions to help our systems handle heavy use, we cannot promise
complete reliability under all circumstances. If you are experiencing problems,
you can make your transactions by writing our Operations Center.


DISRUPTIVE TRANSFER ACTIVITY

You should note that the Contract is not designed for professional "market
timing" organizations, or other organizations or individuals engaging in a
market timing strategy. The Contract is not designed to accommodate programmed
transfers, frequent transfers or transfers that are large in relation to the
total assets of the underlying portfolio.

Frequent transfers, including market timing and other program trading or
short-term trading strategies, may be disruptive to the underlying portfolios
in which the subaccounts invest. Disruptive transfer activity may adversely
affect performance and the interests of long-term investors by requiring a
portfolio to maintain larger amounts of cash or to liquidate portfolio holdings
at a disadvantageous time or price. For example, when market timing occurs, a
portfolio may have to sell its holdings to have the cash necessary to redeem
the market timer's investment. This can happen when it is not advantageous to
sell any securities, so the portfolio's performance may be hurt. When large
dollar amounts are involved, market timing can also make it difficult to use
long-term investment strategies because a portfolio cannot predict how much
cash it will have to invest. In addition, disruptive transfers or purchases and
redemptions of portfolio investments may impede efficient portfolio management
and impose increased transaction costs, such as brokerage costs, by requiring
the portfolio manager to effect more frequent purchases and sales of portfolio
securities. Similarly, a portfolio may bear increased administrative costs as a
result of the asset level and investment volatility that accompanies patterns
of excessive or short-term trading. Portfolios that invest a significant
portion of their assets in foreign securities or the securities of small- and
mid-capitalization companies tend to be subject to the risks associated with
market timing and short-term trading strategies to a greater extent than
portfolios that do not. Securities trading in overseas markets present time
zone arbitrage opportunities when events affecting portfolio securities values
occur after the close of the overseas market but prior to the close of the U.S.
markets. Securities of small- and mid-capitalization companies present
arbitrage opportunities because the market for such securities may be less
liquid than the market for securities of larger companies, which could result
in pricing inefficiencies. Please see the prospectuses for the underlying
portfolios for more information on how portfolio shares are priced.

We currently use the procedures described below to discourage disruptive
transfer activity. You should understand, however, that these procedures are
subject to the following limitations: (1) they primarily rely on the policies
and procedures implemented by the underlying portfolios; (2) they do not
eliminate the possibility that disruptive transfer activity, including market
timing, will occur or that portfolio performance will be affected by such
activity; and (3) the design of market timing procedures involves inherently
subjective judgments, which we seek to make in a fair and reasonable manner
consistent with the interests of all policy and contract owners.

We currently require that any transfer request that would result in an
aggregated transfer amount of $250,000 or more in a single day must be
submitted in writing to our customer service office by U.S. mail (first class).
Overnight mail is not permitted for those transfer requests. We monitor the
$250,000 daily threshold on a monthly basis and combine transfer activities for
all Contracts with the same or related owner. We do not permit exceptions to
this policy. We may change this policy, and any new or revised policy will
apply to all Contractholders uniformly.


We offer subaccounts with underlying portfolios that are part of the AXA
Premier VIP Trust and EQ Advisors Trust, as well as subaccounts with underlying
portfolios of outside trusts with which AXA Equitable has entered participation
agreements (the "unaffiliated trusts" and, collectively with AXA Premier VIP
Trust and EQ Advisors Trust, the "trusts"). The trusts have adopted policies
and procedures regarding disruptive transfer activity. They discourage frequent
purchases and redemptions of portfolio shares and will not make special
arrangements to accommodate such transactions. They aggregate inflows and
outflows for each portfolio on a daily basis. On any day when a portfolio's net
inflows or outflows exceed an established monitoring threshold, the trust
obtains from us contract owner trading activity. The affiliated trusts
currently consider transfers into and out of (or vice versa) the same
subaccount within a five business day period as potentially disruptive transfer
activity.


When a Contract is identified in connection with potentially disruptive
transfer activity for the first time, a letter is sent to the Contract owner
explaining that there is a policy against disruptive transfer activity and that
if such activity continues certain transfer privileges may be eliminated. If
and when the contract owner is identified a second time as engaged in
potentially disruptive transfer activity under the Contract, we currently
prohibit the use of voice, fax and automated transaction services. We currently
apply such action for the remaining life of each affected contract. We or a
trust may change the definition of potentially disruptive transfer activity,
the monitoring procedures and thresholds, any notification procedures, and the
procedures to restrict


                                     DETAILED INFORMATION ABOUT THE CONTRACT  20





this activity. Any new or revised policies and procedures will apply to all
contract owners uniformly. We do not permit exceptions to our policies
restricting disruptive transfer activity.


Each unaffiliated trust may have its own policies and procedures regarding
disruptive transfer activity. If an unaffiliated trust advises us that there
may be disruptive activity from one of our contract owners, we will work with
the unaffiliated trust to review contract owner trading activity. Each trust
reserves the right to reject a transfer that it believes, in its sole
discretion, is disruptive (or potentially disruptive) to the management of one
of its portfolios. Please see the prospectuses for the trusts for more
information.


It is possible that a trust may impose a redemption fee designed to discourage
frequent or disruptive trading by contract owners. As of the date of this
prospectus, the trusts had not implemented such a fee. If a redemption fee is
implemented by a trust, that fee, like any other trust fee, will be borne by
the contract owner.

Contract owners should note that it is not always possible for us and the
underlying trusts to identify and prevent disruptive transfer activity. In
addition, because we do not monitor for all frequent trading at the separate
account level, contract owners may engage in frequent trading which may not be
detected, for example, due to low net inflows or outflows on the particular
day(s). Therefore, no assurance can be given that we or the trusts will
successfully impose restrictions on all potentially disruptive transfers.
Because there is no guarantee that disruptive trading will be stopped, some
contract owners may be treated differently than others, resulting in the risk
that some contract owners may be able to engage in frequent transfer activity
while others will bear the effect of that frequent transfer activity. The
potential effects of frequent transfer activity are discussed above.


TERMINATION OF THE CONTRACT

The Contract will remain in effect until the earlier of:

(1)  the date the Contract is surrendered in full,

(2)  the date annuity payments start,

(3)  the Contract Anniversary on which, after deduction for any annual contract
     charge then due, no Fund Value in the subaccounts and the Guaranteed
     Interest Account with Market Value Adjustment remains in the Contract, or

(4)  the date the death benefit is payable under the Contract.


21  DETAILED INFORMATION ABOUT THE CONTRACT





5. DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT


--------------------------------------------------------------------------------

GENERAL

The Guaranteed Interest Account with Market Value Adjustment is an allocation
option available under the Contract. The Guaranteed Interest Account with
Market Value Adjustment may not be available in every state jurisdiction.

The guarantees associated with the Guaranteed Interest Account with Market
Value Adjustment are borne exclusively by the Company. The guarantees
associated with the Guaranteed Interest Account with Market Value Adjustment
are legal obligations of the Company. Fund Values allocated to the Guaranteed
Interest Account with Market Value Adjustment are held in the General Account
of the Company. Amounts allocated to the General Account of the Company are
subject to the liabilities arising from the business the Company conducts. The
Company has sole investment discretion over the investment of the assets of its
General Account. Owners having allocated amounts to a particular Accumulation
Period of the Guaranteed Interest Account with Market Value Adjustment,
however, will have no claim against any particular assets of the Company.

The Guaranteed Interest Account with Market Value Adjustment provides for a
Specified Interest Rate, which is a guaranteed interest rate that will be
credited as long as any amount allocated to the Guaranteed Interest Account
with Market Value Adjustment is not distributed for any reason prior to the
Maturity Date of the particular Accumulation Period chosen by the Owner.
Generally, a 3-year Accumulation Period offers guaranteed interest at a
Specified Interest Rate over three years, a 5-year Accumulation Period offers
guaranteed interest at a Specified Interest Rate over five years, and so on.
Because the Maturity Date is the Monthly Contract Anniversary immediately prior
to the 3, 5, 7 or 10 year anniversary of the start of the Accumulation Period,
the Accumulation Period may be up to 31 days shorter than the 3, 5, 7 or 10
years, respectively.

Although the Specified Interest Rate will continue to be credited as long as
Fund Value remains in an Accumulation Period of the Guaranteed Interest Account
with Market Value Adjustment prior to the Maturity Date of that Accumulation
Period, surrenders or transfers (including transfers to the Loan Account as a
result of a request by the Owner for a Loan) will be subject to a Market Value
Adjustment, as described below. Market Value Adjustments do not apply upon
annuitization under Settlement Option 3 or 3A.

Market Value Adjustments do not apply for partial or full surrenders or
transfers requested within 30 days before the end of the Accumulation Period,
nor to any benefits paid upon the death of the Annuitant. The Market Value
Adjustment does apply to benefits paid upon death of the Owner. Market Value
Adjustments also do not apply to contracts issued in certain states.

GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT

The Guaranteed Interest Account with Market Value Adjustment is a part of the
Company's General Account and consists of all the Company's assets other than
assets allocated to segregated investment accounts of the Company, including
MONY America Variable Account A.
--------------------------------------------------------------------------------
MARKET VALUE ADJUSTMENT -- An amount added to or deducted from the amount
surrendered or transferred from the Guaranteed Interest Account with Market
Value Adjustment for contracts issued in certain states.
ACCUMULATION PERIOD -- Currently 3, 5, 7 and 10 years. The Period starts on the
Business Day that falls on, or next follows the date the Purchase Payment is
transferred into the Guaranteed Interest Account with Market Value Adjustment
and ends on the monthly contract anniversary immediately prior to the last day
of that Period. (THE ACCUMULATION PERIOD IS LIMITED TO ONE YEAR FOR CONTRACTS
ISSUED IN THE STATES OF MARYLAND, NEW JERSEY, OKLAHOMA, OREGON, SOUTH CAROLINA,
TEXAS, WASHINGTON AND THE COMMONWEALTHS OF MASSACHUSETTS AND PENNSYLVANIA.)
CONTRACT YEAR -- Any period of twelve (12) months commencing with the Effective
Date and each Contract Anniversary thereafter.
CONTRACT ANNIVERSARY -- An anniversary of the Effective Date of the Contract.
GENERAL ACCOUNT -- The General Account of the Company which consists of all of
the Company's assets other than those assets allocated to the Company's
separate accounts.
--------------------------------------------------------------------------------

ALLOCATIONS TO THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT

There are three sources from which allocations to the Guaranteed Interest
Account with Market Value Adjustment may be made:

(1)  an initial Purchase Payment made under a Contract may be wholly or
     partially allocated to the Guaranteed Interest Account with Market Value
     Adjustment;

(2)  a subsequent or additional Purchase Payment made under a Contract may be
     partially or wholly allocated to the Guaranteed Interest Account with
     Market Value Adjustment; and

(3)  amounts transferred from Subaccounts available under the Contract may be
     wholly or partially allocated to the Guaranteed Interest Account with
     Market Value Adjustment.


There is no minimum amount of any allocation of either Purchase Payments or
transfers of Fund Value to the Guaranteed Interest Account with Market Value
Adjustment. The 1-year Accumulation Period (which is limited to certain states
in which there is no Market Value Adjustment), requires the Guaranteed Interest
Account to have a minimum Fund Value of $2,500 when an allocation to said
account is chosen.

SPECIFIED INTEREST RATES AND THE ACCUMULATION PERIODS

SPECIFIED INTEREST RATES


The Specified Interest Rate, at any given time, is the rate of interest
guaranteed by the Company to be credited to allocations made to the
Accumulation Period for the Guaranteed Interest Account with Market Value
Adjustment chosen by the Owner, so long as no portion of the


 DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT  22





allocation is distributed for any reason prior to the Maturity Date of the
Accumulation Period. Different Specified Interest Rates may be established for
the four different Accumulation Periods which are currently available (3, 5, 7
and 10 years). (The Accumulation Period is limited to one year for contracts
issued in the states of Maryland, New Jersey, Oklahoma, Oregon, South Carolina,
Texas and Washington and the Commonwealths of Massachusetts and Pennsylvania.)

The Company declares Specified Interest Rates for each of the available
Accumulation Periods from time to time. Normally, new Specified Interest Rates
will be declared monthly; however, depending on interest rate fluctuations,
declarations of new Specified Interest Rates may occur more or less frequently.
The Company observes no specific method in the establishment of the Specified
Interest Rates, but generally will attempt to declare Specified Interest Rates
which are related to interest rates associated with fixed-income investments
available at the time and having durations and cash flow attributes compatible
with the Accumulation Periods then available for the Guaranteed Interest
Account with Market Value Adjustment. In addition, the establishment of
Specified Interest Rates may be influenced by other factors, including
competitive considerations, administrative costs and general economic trends.
The Company has no way of predicting what Specified Interest Rates may be
declared in the future and there is no guarantee that the Specified Interest
Rate for any of the Accumulation Periods will exceed the guaranteed minimum
effective annual interest rate of 3.50%. OWNERS BEAR THE RISK THAT THE
SPECIFIED INTEREST RATE WILL NOT EXCEED THE GUARANTEED MINIMUM RATE.

The period of time during which a particular Specified Interest Rate is in
effect for new allocations to the then available Accumulation Periods is
referred to as the Investment Period. All allocations made to an Accumulation
Period during an Investment Period are credited with the Specified Interest
Rate in effect. An Investment Period ends only when a new Specified Interest
Rate relative to the Accumulation Period in question is declared. Subsequent
declarations of new Specified Interest Rates have no effect on allocations made
to Accumulation Periods during prior Investment Periods. All such prior
allocations will be credited with the Specified Interest Rate in effect when
the allocation was made for the duration of the Accumulation Period selected.

Information concerning the Specified Interest Rates in effect for the various
Accumulation Periods can be obtained by contacting an agent of the Company who
is also a registered representative of AXA Advisors, LLC or by calling the
following toll free telephone number: (800) 487-6669.

The Specified Interest Rate is credited on a daily basis to allocations made to
an Accumulation Period elected by the Owner, resulting in an annual effective
yield which is guaranteed by the Company, unless amounts are surrendered,
transferred or paid out on death of Annuitant from that Accumulation Period for
any reason prior to the Maturity Date for that Accumulation Period. The
Specified Interest Rate will be credited for the entire Accumulation Period. If
amounts are surrendered or transferred from the Accumulation Period for any
reason prior to the Maturity Date, a Market Value Adjustment will be applied to
the amount surrendered or transferred.


CREDITING OF INTEREST

The entire initial Purchase Payment always earns interest at a rate not less
than 3.50% per year until the end of the right to return contract period. When
the right to return contract period ends, the entire initial Purchase Payment
plus interest earned is transferred to the selected subaccounts and/or
Guaranteed Interest Account with Market Value Adjustment accumulation periods.

Any Net Purchase Payments you as Owner of the Contract allocate to the
Guaranteed Interest Account with Market Value Adjustment will be credited with
interest at the rate declared by the Company for the specified period selected.
The Company guarantees that the rate credited will not be less than 3.50%
annually (0.0094%, compounded daily). You bear the risk that we will not
declare an annual interest rate in excess of 3.50% per year. If you allocate
Purchase Payments (or transfer fund value) to the Guaranteed Interest Account
with Market Value Adjustment, you will choose between Accumulation Periods of
3, 5, 7, or 10 years for Contracts issued in most states. The Accumulation
Period is limited to one year for contracts issued in the states of Maryland,
New Jersey, Oklahoma, Oregon, South Carolina, Texas and Washington and the
Commonwealths of Massachusetts and Pennsylvania. Before the beginning of each
calendar month, the Company will declare interest rates for each period, if
those rates will be higher than the guaranteed rate. Each interest rate
declared by the Company will be applicable for all Net Purchase Payments
received or transfers from MONY America Variable Account A completed within the
period during which it is effective. Amounts you allocate to the Accumulation
Period you select will receive this interest rate for the entire Accumulation
Period. Within 45 days, but not less than 15 days before the Accumulation
Period expires, we will notify you of the new rates we are then declaring. When
the period expires you can (1) elect a new Accumulation Period of 3, 5, 7, or
10 years (except in certain states where the Accumulation Period is limited to
a one year period) or (2) you may elect to transfer the amounts allocated to
the expiring Accumulation Period to MONY America Variable Account A. If you
make no election within 30 days of the end of an Accumulation Period, the
entire amount allocated to the expiring Accumulation Period will automatically
be held for an Accumulation Period of the same length. If that period will
extend beyond the annuity starting date or if that period is no longer offered,
the money will be transferred into the Money Market subaccount.

ACCUMULATION PERIODS

For each Accumulation Period, the Specified Interest Rate in effect at the time
of the allocation to that Accumulation Period is guaranteed. An Accumulation
Period always ends on a Maturity Date, which is the Monthly Contract
Anniversary immediately prior to the 3, 5, 7 or 10 year anniversary of the
start of the Accumulation Period. Therefore, the Specified Interest Rate may be
credited for up to 31 days less than the full 3, 5, 7 or 10 years. (The
Accumulation Period is limited to one year for contracts issued in the states
of Maryland, New Jersey, Oklahoma, Oregon, South Carolina, Texas and Washington
and the Commonwealths of Massachusetts and Pennsylvania.)

For example, if the Effective Date of a Contract is August 10, 2000 and an
allocation is made to a 10 year Accumulation Period on August 15, 2000 and the
funds for a new Purchase Payment are received on that day, the Accumulation
Period will begin on August 15, 2000 and end on August 10, 2010, during which
period the Specified Interest Rate will be credited.

All Accumulation Periods for the 3, 5, 7, and 10 year Accumulation Periods,
respectively, will be determined in a manner consistent with the foregoing
example.

END OF ACCUMULATION PERIODS

At least fifteen days and at most forty-five days prior to the end of an
Accumulation Period, the Company will send notice to the Owner of the impending
Maturity Date. The notice will include the projected



23  DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT






Fund Value held in the Accumulation Period on the Maturity Date and will
specify the various options Owners may exercise with respect to the
Accumulation Period:

(1)  During the thirty-day period before the Maturity Date, the Owner may wholly
     or partially surrender the Fund Value held in that Accumulation Period
     without a Market Value Adjustment; however, Surrender Charges under the
     Contract, if applicable, will be assessed.

(2)  During the thirty-day period before the Maturity Date, the Owner may wholly
     or partially transfer the Fund Value held in that Accumulation Period,
     without a Market Value Adjustment, to any Subaccount then available under
     the Contract or may elect that the Fund Value held in that Accumulation
     Period be held for an additional Accumulation Period of the same number of
     years or for another Accumulation Period of a different number of years
     which may at the time be available. A confirmation of any such transfer or
     election will be sent immediately after the transfer or election is
     processed.

(3)  If the Owner does not make an election within thirty days following the
     Maturity Date, the entire Fund Value held in the maturing Accumulation
     Period will be transferred to an Accumulation Period of the same number of
     years as the Accumulation Period which matured. The start of the new
     Accumulation Period is the ending date of the previous Accumulation Period.
     However, if that period would extend beyond the Annuity Starting Date of
     the Contract or if that period is not then made available by the Company,
     the Fund Value held in the maturing Accumulation Period will be
     automatically transferred to the Money Market Subaccount at the end of the
     Maturity Period. A confirmation will be sent immediately after the
     automatic transfer is executed.

During the thirty day period following the Maturity Date, and prior to any of
the transactions set forth in (1), (2), or (3) above, the Specified Value held
in the maturing Accumulation Period will continue to be credited with the
Specified Interest Rate in effect before the Maturity Date.


SURRENDERS, TRANSFERS OR LOANS


When you as Owner request that Contract Fund Value from the Guaranteed Interest
Account with Market Value Adjustment be transferred to MONY America Variable
Account A, surrendered, loaned to you, or used to pay any charge imposed in
accordance with the Contract, you should tell the Company the source by
interest rate Accumulation Period of amounts you request be transferred,
surrendered, loaned, or used to pay charges. If you do not specify an
Accumulation Period, your transaction will be processed using the Accumulation
Periods in which money was most recently allocated.

THE MARKET VALUE ADJUSTMENT

GENERAL INFORMATION REGARDING THE MVA


A surrender or transfer (including a transfer to the Loan Account as a result
of a request by the Owner for a Loan) from the Guaranteed Interest Account with
Market Value Adjustment prior to the Maturity Date of that particular
Accumulation Period, will be subject to a Market Value Adjustment. A Market
Value Adjustment will not apply upon annuitization under Settlement Option 3 or
3A, or upon payment of a death benefit. The Market Value Adjustment is
determined by the multiplication of an MVA Factor by the Specified Value, or
the portion of the Specified Value being surrendered or transferred (including
transfers for the purpose of obtaining a Loan). The Specified Value is the
amount of the allocation of Purchase Payments and transfers of Fund Value to an
Accumulation Period of the Guaranteed Interest Account with Market Value
Adjustment, plus interest accrued at the Specified Interest Rate minus prior
distributions. The Market Value Adjustment may either increase or decrease the
amount of the distribution. It will not apply to requests for transfer or full
or partial surrenders received at our administrative office within 30 days
before the end of the applicable Accumulation Period.

The Market Value Adjustment is intended to approximate, without duplicating,
the experience of the Company when it liquidates assets in order to satisfy
contractual obligations. Such obligations arise when Owners request surrenders
or transfers (including transfers for the purpose of obtaining a Loan). When
liquidating assets, the Company may realize either a gain or a loss.

A market value adjustment can increase or decrease the amounts surrendered or
transferred from the Guaranteed Interest Account with Market Value Adjustment
depending on current interest rate fluctuations.

If prevailing interest rates are higher at the time of a surrender or transfer
(including transfers for the purpose of obtaining a Loan) than the Specified
Interest Rate in effect at the time the Accumulation Period commences, the
Company will realize a loss when it liquidates assets in order to process a
surrender or transfer (including transfers for the purpose of obtaining a
Loan); therefore, application of the Market Value Adjustment under such
circumstances will decrease the amount of the surrender or transfer (including
transfers for the purpose of obtaining a Loan).

Generally, if prevailing interest rates are lower than the Specified Interest
Rate in effect at the time the Accumulation Period commences, the Company will
realize a gain when it liquidates assets in order to process a surrender or
transfer (including transfers for the purpose of obtaining a Loan); therefore,
application of the MVA under such circumstances will generally increase the
amount of the surrender or transfer (including transfers for the purpose of
obtaining a Loan).

The Company measures the relationship between prevailing interest rates and the
Specified Interest Rates it declares through the MVA Factor. The MVA Factor is
described more fully below.



THE MVA FACTOR

The formula for determining the MVA Factor is:

                          [(1+a)/(1+b)]((n-t)/12) - 1

Where:

     a =   the Specified Interest Rate for the Accumulation Period from which
           the surrender, transfer or loan is to be taken;

     b =   the Specified Interest Rate declared at the time a surrender or
           transfer is requested for an Accumulation Period equal to the time
           remaining in the Accumulation Period from which the surrender or
           transfer (including transfer to the Loan Account as a result of a
           request by the Owner for a Loan) is requested, plus 0.25%;

     n =   the Accumulation Period from which the surrender or transfer occurs
           in months; and


 DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT  24






     t =   the number of elapsed months (or portion thereof) in the
           Accumulation Period from which the surrender or transfer occurs.

If an Accumulation Period equal to the time remaining is not issued by the
Company, the rate will be an interpolation between two available Accumulation
Periods. If two such Accumulation Periods are not available, we will use the
rate for the next available Accumulation Period.

If the Company is no longer declaring rates on new payments, we will use
Treasury yields adjusted for investment risk as the basis for the Market Value
Adjustment.

The MVA Factor shown above also accounts for some of the administrative and
processing expenses incurred when fixed-interest investments are liquidated.
This is represented in the addition of 0.25% in the MVA Factor.

The MVA Factor will be multiplied by that portion of the Specified Value being
surrendered, transferred, or distributed for any other reason. If the result is
greater than zero, a gain will be realized by the Owner; if less than zero, a
loss will be realized. If the MVA Factor is exactly zero, no gain or loss will
be realized by the Owner.


INVESTMENTS

Amounts allocated to the Guaranteed Interest Account with Market Value
Adjustment are transferred to the General Account of the Company. Amounts
allocated to the General Account of the Company are subject to the liabilities
arising from the business the Company conducts. This is unlike amounts
allocated to the Subaccounts of the MONY America Variable Account A, which are
not subject to the liabilities arising from the business the Company conducts.

The Company has sole investment discretion over the investment of the assets of
the General Account. We will invest these amounts primarily in investment-grade
fixed income securities including: securities issued by the U.S. Government or
its agencies or instrumentalities, which issues may or may not be guaranteed by
the U.S. Government; debt securities that have an investment grade, at the time
of purchase, within the four highest grades assigned by Moody's Investor
Services, Inc., Standard & Poor's Corporation, or any other nationally
recognized rating service; mortgage-backed securities collateralized by real
estate mortgage loans or securities collateralized by other assets, that are
insured or guaranteed by the Federal Home Loan Mortgage Association, the
Federal National Home Mortgage Association, or the Government National Mortgage
Association, or that have an investment grade at the time of purchase within
the four highest grades described above; commercial and agricultural mortgage
loans; other debt instruments; commercial paper; cash or cash equivalents.

Variable annuity Owners having allocated amounts to a particular Accumulation
Period of the Guaranteed Interest Account with Market Value Adjustment will not
have a direct or indirect interest in these investments, nor will they have a
claim against any particular assets of the Company. The overall investment
performance of the General Account will not increase or decrease their claim
against the Company.

There is no specific formula for establishing Specified Interest Rates. The
Specified Interest Rates declared by the Company for the various Accumulation
Periods will not necessarily correspond to the performance of any group of
assets of the General Account. We will consider certain factors in determining
these rates, such as regulatory and tax environment, sales commissions,
administrative expenses borne by us, and competitive factors. The Company's
management will make the final determination of these rates. However, the
Specified Interest Rate will never be less than 3.50%.


25  DESCRIPTION OF THE GUARANTEED INTEREST ACCOUNT WITH MARKET VALUE ADJUSTMENT





6. SURRENDERS



--------------------------------------------------------------------------------

The Owner may elect to make a surrender of all or part of the Contract's Fund
Value provided it is:

o   on or before the annuity payments start, and

o   during the lifetime of the Annuitant.

Any such election shall specify the amount of the surrender. The surrender will
be effective on the date a proper written request is received by the Company at
its Operations Center.

The amount of the surrender may be equal to the Contract's Cash Value, which is
its Fund Value less:

(1)    any applicable surrender charge,

(2)    any applicable Market Value Adjustment, and

(3)    any outstanding debt.

The Surrender may also be for a lesser amount (a "partial surrender").
Requested partial surrenders that would leave a Cash Value of less than $1,000
are treated and processed as a full surrender. In such case, the entire Cash
Value will be paid to the Owner. For a partial surrender, any surrender charge
or any applicable market value adjustment will be in addition to the amount
requested by the Owner.

A surrender will result in the cancellation of units of the particular
subaccounts and the withdrawal of amounts credited to the Guaranteed Interest
Account Accumulation Periods as chosen by the Owner. The aggregate value of the
surrender will be equal to the dollar amount of the surrender plus, if
applicable, any surrender charge and any applicable market value adjustment.
For a partial surrender, the Company will cancel Units of the particular
subaccounts and withdraw amounts from the Guaranteed Interest Account with
Market Value Adjustment Accumulation Period under the allocation specified by
the Owner. The unit value will be calculated as of the Business Day the
surrender request is received. Allocations may be by either amount or
percentage. Allocations by percentage must be in whole percentages (totaling
100%). At least 10% of the partial surrender must be allocated to any
subaccount or an Accumulation Period in the Guaranteed Interest Account with
Market Value Adjustment designated by the Owner. The request will not be
accepted if:

o    there is insufficient Fund Value in the Guaranteed Interest Account with
     Market Value Adjustment or a subaccount to provide for the requested
     allocation against it, or

o    the request is incomplete or incorrect.

Any surrender charge will be allocated against the Guaranteed Interest Account
with Market Value Adjustment and each subaccount in the same proportion that
each allocation bears to the total amount of the partial surrender. Contracts
issued in the States of Maryland, New Jersey, Oklahoma, South Carolina, Texas
and Washington and the Commonwealths of Massachusetts and Pennsylvania, to the
extent the Owner allocates investments to the Guaranteed Interest Account, must
maintain a minimum Fund Value in the Guaranteed Interest Account of $2,500.

The amount of any surrender or transfer payable from MONY America Variable
Account A will be paid in accordance with the requirements of state insurance
departments and the 1940 Act. However, the Company may be permitted to postpone
such payment under the 1940 Act. Postponement is currently permissible only for
any period during which:

(1)  the New York Stock Exchange is closed other than customary weekend and
     holiday closings, or

(2)  trading on the New York Stock Exchange is restricted as determined by the
     Securities and Exchange Commission, or

(3)  an emergency exists as a result of which disposal of securities held by the
     Fund is not reasonably practicable or it is not reasonably practicable to
     determine the value of the net assets of the Fund.

Any surrender involving payment from amounts credited to the Guaranteed
Interest Account with Market Value Adjustment may be postponed, at the option
of the Company, for up to 6 months from the date the request for a surrender is
received by the Company. Surrenders involving payment from the Guaranteed
Interest Account with Market Value Adjustment may in certain circumstances and
in certain states also be subject to a market value adjustment, in addition to
a surrender charge. The Owner may elect to have the amount of a surrender
settled under one of the settlement options of the Contract. (See "Annuity
provisions".)

Contracts offered by this prospectus may be issued in connection with
retirement plans meeting the requirements of certain sections of the Internal
Revenue Code. Owners should refer to the terms of their particular retirement
plan for any limitations or restrictions on cash surrenders.

The tax results of a surrender should be carefully considered. (See "Federal
tax status".)

Please note: if mandated under applicable law, we may be required to reject a
Purchase Payment. In addition, we may also be required to block an Owner's
account and thereby refuse to honor any request for transfers, partial
surrenders, loans, or death benefits until instructions are secured from the
appropriate regulator. We may be required to provide additional information
about your account to government regulators.


                                                                  SURRENDERS  26





7. LOANS



--------------------------------------------------------------------------------

Qualified Contracts issued under an Internal Revenue Code Section 401(k) plan
will have a loan provision (except in the case of contracts issued in Vermont)
under which a loan can be taken using the Contract as collateral for the loan.
All of the following conditions apply in order for the amount to be considered
a loan, rather than a (taxable) partial surrender:

o    The term of the loan must be 5 years or less.

o    Repayments are required at least quarterly and must be substantially level.

o    The loan amount is limited to certain dollar amounts as specified by the
     IRS.

The Owner (Plan Trustee) must certify that these conditions are satisfied.

In any event, the maximum outstanding loan on a Contract is 50% of the Fund
Value in the subaccounts and/or the Guaranteed Interest Account with Market
Value Adjustment. Loans are not permitted before the end of the right to return
contract period. In requesting a loan, the Owner must specify the subaccounts
from which Fund Value equal to the amount of the loan requested will be taken.
Loans from the Guaranteed Interest Account with Market Value Adjustment are not
taken until Fund Value in the subaccounts is exhausted. If Fund Value must be
taken from the Guaranteed Interest Account with Market Value Adjustment in
order to provide the Owner with the amount of the loan requested, the Owner
must specify the Accumulation Periods from which Fund Values equal to such
amount will be taken. If the Owner fails to specify subaccounts and
Accumulation Periods, the request for a loan will be returned to the Owner.

Values are transferred to a loan account that earns interest at an annual rate
of 3.50%. The annual loan interest rate charged on outstanding loan amounts
will be 6%. If interest is not repaid each year, it will be added to the
principal of the loan.

Loan repayments must be specifically earmarked as loan repayment and will be
allocated to the subaccounts and/or the Guaranteed Interest Account with Market
Value Adjustment using the most recent payment allocation on record. Otherwise,
we will treat the payment as a Net Purchase Payment.
--------------------------------------------------------------------------------
LOAN -- Available under a Contract issued under Section 401(k) of the Code;
subject to availability. To be considered a Loan: (1) the term must be no more
than five years, (2) repayments must be at least quarterly and substantially
level, and (3) the amount is limited to dollar amounts specified by the Code,
not to exceed 50% of the Fund Value.
LOAN ACCOUNT -- A part of the General Account where Fund Value is held as
collateral for a loan. An Owner may transfer Fund Value in the Subaccounts,
and/or Guaranteed Interest Account with Market Value Adjustment to the Loan
Account.
--------------------------------------------------------------------------------

27  LOANS





8. DEATH BENEFIT



--------------------------------------------------------------------------------

DEATH BENEFIT PROVIDED BY THE CONTRACT

The Company will pay a death benefit to the Beneficiary if:

(1)  the Annuitant dies, and

(2)  the death occurs before the annuity payments start.

The amount of the death benefit will be the greater of:

(1)  the Fund Value less any outstanding debt on the date of the Annuitant's
     death;

(2)  the Purchase Payments paid, less any partial surrenders and their surrender
     charges and market value adjustment and less any outstanding debt; or

(3)  an enhanced death benefit.

If there are funds allocated to the Guaranteed Interest Account with market
value adjustment at the time of death, any applicable market value adjustment
will be waived. If the death of the Annuitant occurs on or after the annuity
payments start, no death benefit will be payable except as may be provided
under the settlement option elected.


In general, on the death of an Owner who is not the Annuitant, amounts must be
distributed from the Contract. (See "Provisions required by Section 72(s) of
the Code" later in this prospectus.) We will impose applicable surrender
charges. (See "Charges and deductions" later in this prospectus.)


ENHANCED DEATH BENEFIT OPTIONS

Your Contract provides a choice of two enhanced death benefit options when it
is issued. If the Annuitant is age 0-75, the Owner may choose either enhanced
death benefit -- 5 Year or enhanced death benefit -- 1 Year described below. If
the Annuitant does not choose an option when the Contract is issued, the
Annuitant will automatically receive the enhanced death benefit -- 5 Year. If
your Contract was issued on or before August 16, 2000, you may have elected the
enhanced death benefit -- 1 Year during the period from August 16, 2000 to
September 22, 2000. Owners with these Contracts not making the election will
retain the enhanced death benefit -- 5 Year.

ENHANCED DEATH BENEFIT -- 5 YEAR

On the 5th Contract anniversary and each subsequent 5th Contract anniversary
prior to the Annuitant's 71st birthday, the enhanced death benefit may be
increased. If the Annuitant is age 65 or over on the date of issue, the
enhanced death benefit will be recalculated once on the 5th Contract
anniversary. Thereafter the enhanced death benefit remains at its last value.

ENHANCED DEATH BENEFIT -- 1 YEAR

On the first Contract Anniversary and each subsequent Contract Anniversary
prior to the Annuitant's 80th birthday, the enhanced death benefit may be
increased. After the Annuitant reaches age 80, this enhanced death benefit
provision expires. This option may not be currently available in all states.

AMOUNT OF THE ENHANCED DEATH BENEFIT PAYABLE ON DEATH UNDER ENHANCED DEATH
BENEFIT OPTIONS


The recalculated enhanced death benefit is equal to the greater of:

(1)  the Fund Value on the date the enhanced death benefit is to be
     recalculated; and

(2)  the current enhanced death benefit proportionately reduced by any partial
     surrenders including surrender charges and any applicable market value
     adjustments assessed since the last recalculation of the enhanced death
     benefit.

The enhanced death benefit payable under both enhanced death benefit options is
the enhanced death benefit on the date of death of the Annuitant, reduced
proportionately for each partial surrender (including surrender charges and
market value adjustments, if applicable) since the last recalculation date and
less any outstanding debt.

In no event will the enhanced death benefit payable on death exceed 200% of:

o    the total Purchase Payments reduced proportionately for each partial
     surrender (including surrender charges and applicable market value
     adjustments,), and less

o    any outstanding debt.

The proportionate reduction for each partial surrender will be equal to:

(1)  the amount of that partial surrender (including any surrender charges and
     applicable Market Value Adjustment assessed), divided by

(2)  the Fund Value immediately before that partial surrender, multiplied by,


(3)  the enhanced death benefit immediately before the surrender.

Once the last value is set for the enhanced death benefit, it will not be
recalculated. The last value is set for the 5 Year option prior to the
Annuitant's 71st birthday or on the first 5th anniversary if the Contract is
purchased on or after the Annuitant's age 65. The last value is set for the 1
Year option on the Contract Anniversary prior to the Annuitant's age 80. After
the Annuitant reaches age 80, this enhanced death benefit provision expires.

All other basic death benefits as described in this prospectus continue to
apply. The largest death benefit under any of these provisions will be paid.

The cost of an enhanced death benefit option is reflected in the mortality and
expense risk charge.

ELECTION AND EFFECTIVE DATE OF ELECTION

The Owner may elect to have the death benefit of the Contract applied under one
of four settlement options to effect an annuity for the Beneficiary as payee
after the death of the Annuitant. The election must take place:

(1)  during the lifetime of the Annuitant, and

(2)  before the annuity payments start.

                                                               DEATH BENEFIT  28





If no election of a settlement option for the death benefit is in effect on the
date when proceeds become payable, the Beneficiary may elect:

(1)  to receive the death benefit in the form of a lump sum payment; or

(2)  to have the death benefit applied under one of the settlement options.

(See "Settlement options.") If an election by the payee is not received by the
Company within one month following the date proceeds become payable, the payee
will be considered to have elected a lump sum payment. Either election
described above may be made by filing a written election with the Company in
such form as it may require. Any proper election of a method of settlement of
the death benefit by the Owner will become effective on the date it is signed.
However, any election will be subject to any payment made or action taken by
the Company before receipt of the notice at the Company's Operations Center.

Settlement option availability may be restricted by the terms of any applicable
retirement plan and any applicable legislation for any limitations or
restrictions on the election of a method of settlement and payment of the death
benefit.

PAYMENT OF DEATH BENEFIT

If the death benefit is to be paid in one sum to the Beneficiary, payment will
be made within seven (7) days of the date:

(1)  the election becomes effective, or

(2)  the election is considered to become effective, and

(3)  due proof of death of the Annuitant is received.

The Company may be permitted to postpone such payment from amounts payable from
MONY America Variable Account A under the 1940 Act. If the death benefit is to
be paid in one sum to the Successor Beneficiary, or to the estate of the
deceased Annuitant, payment will be made within seven (7) days of the date due
proof of the death of the Annuitant and the Beneficiary is received by the
Company. Unless another election is made, the death benefit proceeds will be
transferred to an interest bearing checking account. The Beneficiary may make
partial or full withdrawals from such account through a checkbook provided to
the Beneficiary.


29  DEATH BENEFIT





9. CHARGES AND DEDUCTIONS



--------------------------------------------------------------------------------
The following table summarizes the charges and deductions under the Contract
(See "Summary of the Contract -- Fee tables" for more detailed information):



-----------------------------------------------------------------------------------------------------------------------------
DEDUCTIONS FROM PURCHASE PAYMENTS
-----------------------------------------------------------------------------------------------------------------------------
                                                         
Tax charge                                                  Range for State and local -- 0%-3.50%(1).
                                                            Federal -- Currently 0% (Company reserves the right to charge in
                                                            the future.)
-----------------------------------------------------------------------------------------------------------------------------
DAILY DEDUCTIONS FROM MONY AMERICA VARIABLE ACCOUNT A
-----------------------------------------------------------------------------------------------------------------------------
Mortality & expense risk charge                             Maximum daily rate -- 0.003699%
Annual Rate deducted daily from average daily net assets    Maximum Annual rate -- 1.35%
-----------------------------------------------------------------------------------------------------------------------------
DEDUCTIONS FROM FUND VALUE
-----------------------------------------------------------------------------------------------------------------------------
Annual contract charge                                      Maximum of $50 ($30 in some states) on 30 days written notice
                                                            Current charge is $0
-----------------------------------------------------------------------------------------------------------------------------
Transaction and other charges                               Maximum of $25
Transfer charge                                             Current charge is $0
-----------------------------------------------------------------------------------------------------------------------------
Surrender charge                                            See grading schedule and "Charges and deductions -- Charges
Grades from 7% to 0% of Fund Value surrendered based on a   against fund value" for details of how it is computed.
schedule.
-----------------------------------------------------------------------------------------------------------------------------
Loan interest spread                                        2.50%
-----------------------------------------------------------------------------------------------------------------------------


(1)    Company currently assumes responsibility; current charge to Owner 0%.


The following provides additional details of the charges and deductions under
the Contract.

The amount of the charge may not necessarily correspond to the costs associated
with providing the services or benefits indicated by the designation of the
charge. For example, the surrender charge we collect may not fully cover all of
the sales and distribution expenses we actually incur. We also may realize a
profit on one or more of the charges. We may use such profits for any corporate
purpose, including the payment of sales expenses.

DEDUCTIONS FROM PURCHASE PAYMENTS


Deductions may be made from Purchase Payments for a charge for state and local
premium or similar taxes prior to allocation of any Net Purchase Payment among
the subaccounts. Currently, the Company makes no deduction, but may do so with
respect to future Purchase Payments. If the Company is going to make deductions
for such tax from future Purchase Payments, it will give 30 days notice to each
affected Owner.

CHARGES AGAINST FUND VALUE

DAILY DEDUCTION FROM MONY AMERICA VARIABLE ACCOUNT A

MORTALITY AND EXPENSE RISK CHARGE.  The Company assumes mortality and expense
risks. A charge for assuming such risks is deducted daily from the net assets
of MONY America Variable Account A. This daily charge from MONY America
Variable Account A is deducted at a current daily rate equivalent to an annual
rate of 1.35% from the value of the net assets of MONY America Variable Account
A. The rate is guaranteed not to exceed a daily rate equivalent to an annual
rate of 1.35% from the value of the net assets of MONY America Variable Account
A. The charge is deducted from MONY America Variable Account A, and therefore
the subaccounts, on each Business Day. The mortality and expense risk charges
will not be deducted from the Guaranteed Interest Account with Market Value
Adjustment. Where the previous day (or days) was not a Business Day, the
deduction currently on the next Business Day will be 0.003699% (guaranteed not
to exceed 0.003699%) multiplied by the number of days since the last Business
Day.


The Company believes that this level of charge is within the range of industry
practice for comparable individual flexible payment variable annuity contracts.


The mortality risk assumed by the Company is that Annuitants may live for a
longer time than projected. If that occurs, an aggregate amount of annuity
benefits greater than that projected will be payable. In making this
projection, the Company has used the mortality rates from the 1983 Table "a"
(discrete functions without projections for future mortality), with 3.50%
interest. The expense risk assumed is that expenses incurred in issuing and
administering the Contracts will exceed the administrative charges provided in
the Contracts.


If the amount of the charge exceeds the amount needed, the excess will be kept
by the Company in its General Account. If the amount of the charge is
inadequate, the Company will pay the difference out of its General Account.

DEDUCTIONS FROM FUND VALUE

ANNUAL CONTRACT CHARGE.  The Company has primary responsibility for the
administration of the Contract and MONY America Variable Account A. An annual
contract charge helps to reimburse the Company for administrative expenses
related to the maintenance of the Contract. Ordinary administrative expenses
expected to be incurred include premium collection, recordkeeping, processing
death benefit claims and surrenders, preparing and mailing reports, and
overhead costs. In addition, the Company expects to incur certain additional
administrative expenses in connection with the issuance of the Contract,
including the review of applications and the establishment of Contract records.




                                                      CHARGES AND DEDUCTIONS  30






The Company intends to administer the Contract itself through an arrangement
whereby it may buy some administrative services from AXA Equitable and such
other sources as may be available.

Currently, there is no annual contract charge. The Company may in the future
impose an annual contract charge. The charge will never, however, exceed $50.
The Owner will receive a written notice 30 days in advance of any change in the
charge. Any applicable charge will be assessed once per year on the Contract
Anniversary, starting on the first Contract Anniversary.

If imposed, the annual contract charge is deducted from the Fund Value on each
Contract Anniversary before the date annuity payments start.

The amount of the charge will be allocated against the Guaranteed Interest
Account with Market Value Adjustment and each subaccount of MONY America
Variable Account A in the same proportion that the Fund Value in those accounts
bears to the Fund Value of the Contract. The Company does not expect to make
any profit from the annual contract charge.

TRANSFER CHARGE.  Contract value may be transferred among the subaccounts or to
or from the Guaranteed Interest Account with Market Value Adjustment and one or
more of the subaccounts (including transfers made by telephone, if permitted by
the Company). The Company reserves the right to impose a transfer charge for
each transfer instructed by the Owner in a Contract Year. The transfer charge
compensates the Company for the costs of effecting the transfer. The transfer
charge will not exceed $25 (except for contracts issued in the states of South
Carolina and Texas where it will not exceed $10). The Company does not expect
to make a profit from the transfer charge. If imposed, the transfer charge will
be deducted from the Contract's Fund Value held in the subaccount(s) or from
the Guaranteed Interest Account with Market Value Adjustment from which the
first transfer is made.

SURRENDER CHARGE.  A contingent deferred sales charge (called a "surrender
charge") will be imposed when a full or partial surrender is requested or at
the start of annuity benefits if it is during the first eight years of the
Contract.


The surrender charge will never exceed 7% of total Fund Value. The surrender
charge is intended to reimburse the Company for expenses incurred in
distributing the Contract. To the extent such charge is insufficient to cover
all distribution costs, the Company will make up the difference. The Company
will use funds from its General Account, which may contain funds deducted from
MONY America Variable Account A to cover mortality and expense risks borne by
the Company. (See "Charges against fund value -- Mortality and expense risk
charge.")

We impose a surrender charge when a full or partial surrender is made during
the first eight (8) Contract Years, except as provided below.

A surrender charge will not be imposed:

(1)  Against Fund Value surrendered after the eighth Contract Year.

(2)  To the extent necessary to permit the Owner to obtain an amount equal to
     the free partial surrender amount (See "Free partial surrender amount").

(3)  If the Contract is surrendered after the third Contract Year and the
     surrender proceeds are paid under either Settlement Option 3 or Settlement
     Option 3A (See "Settlement options"). The elimination of a Surrender Charge
     in this situation does not apply to contracts issued in the State of Texas.

In no event will the aggregate surrender charge exceed 7% of the Fund Value.
Further, in no event will the surrender charges imposed, when added to any
surrender charges previously paid on the Contract, exceed 9% of aggregate
Purchase Payments made to date for the Contract.

The Owner may specify whether he/she wants the surrender charge to be deducted
from the amount requested for surrender or the Fund Value remaining. If not
specified or if the Fund Value remaining is not sufficient, then the surrender
charge will be deducted from the amount requested for surrender. If it is
specified that the surrender charge will come from the remaining Fund Value and
it is sufficient, then the Company will determine the appropriate amount to be
surrendered in order to pay the surrender charge. Any surrender charge will be
allocated against the Guaranteed Interest Account with Market Value Adjustment
and each subaccount of MONY America Variable Account A in the same proportion
that the amount of the partial surrender allocated against those accounts bears
to the total amount of the partial surrender.

If any surrender from the Guaranteed Interest Account with Market Value
Adjustment occurs prior to the Maturity Date for any particular Accumulation
Period elected by the Owner, the amount surrendered will be subject to a Market
Value Adjustment in addition to Surrender Charges.

No surrender charge will be deducted from Death Benefits except as described in
"Death benefit."

If The MONYMaster variable annuity contract issued by MONY Life Insurance
Company of America has been exchanged for this Contract, a separate effective
date was assigned to this Contract by endorsement for purposes of determining
the amount of any surrender charge. The surrender charge effective date of this
Contract with the endorsement is the effective date of The MONYMaster variable
annuity contract. Your agent can provide further details.

A separate surrender charge effective date does not apply in states where the
endorsement has not been approved. We reserve the right to disallow exchanges
for this Contract at any time.


AMOUNT OF SURRENDER CHARGE.  The amount of the surrender charge is equal to a
varying percentage of Fund Value during the first 8 Contract Years. The
percentage is determined by multiplying the surrender charge percentage for the
Contract Year by the amount of Fund Value requested as follows:





--------------------------------------------------------
SURRENDER CHARGE PERCENTAGE TABLE
--------------------------------------------------------
             
CONTRACT YEAR           SURRENDER CHARGE (AS A
                        PERCENTAGE OF FUND VALUE
                        SURRENDERED)
--------------------------------------------------------
1                       7%
--------------------------------------------------------
2                       7
--------------------------------------------------------
3                       6
--------------------------------------------------------
4                       6
--------------------------------------------------------
5                       5
--------------------------------------------------------
6                       4
--------------------------------------------------------
7                       3
--------------------------------------------------------
8                       2
--------------------------------------------------------
9 (or more)             0
--------------------------------------------------------





31  CHARGES AND DEDUCTIONS







The amount of the surrender charge is in addition to any applicable Market
Value Adjustment that may be made if the surrender is made from Fund Value in
the Guaranteed Interest Account with Market Value Adjustment. (See "Guaranteed
Interest Account with Market Value Adjustment -- Surrenders" for further
details.)

FREE PARTIAL SURRENDER AMOUNT.  The surrender charge may be reduced by using
the free partial surrender amount provided for in the Contract. The surrender
charge will not be deducted in the following circumstances:

(1)  For Qualified Contracts, (other than contracts issued for IRA and SEP-IRA),
     an amount each Contract Year up to the greater of:

     (a)   $10,000 (but not more than the Contract's Fund Value), or

     (b)   10% of the Contract's Fund Value at the beginning of the Contract
           Year (except, if the surrender is requested during the first
           Contract Year, then 10% of the Contract's Fund Value at the time the
           first surrender is requested).

(2)  For Non-Qualified Contracts (and contracts issued for IRA and SEP-IRA), an
     amount up to 10% of the Fund Value at the beginning of the Contract Year
     (except, if the surrender is requested during the first Contract Year, then
     10% of the Contract's Fund Value at the time the first surrender is
     requested) may be received in each Contract Year without a surrender
     charge.

Free partial surrenders may only be made to the extent Cash Value in the
subaccounts and/or Guaranteed Interest Account is available. For example, the
Fund Value in MONY America Variable Account A could decrease (due to
unfavorable investment experience) after part of the 10% was withdrawn. In that
case it is possible that there may not be enough Cash Value to provide the
remaining part of the 10% free partial surrender amount.

Contract Fund Value here means the Fund Value in the subaccounts (and the
Guaranteed Interest Account with Market Value Adjustment not the Loan Account).
This reduction of surrender charge does not affect any applicable Market Value
Adjustment that may be made if the surrender is made from Fund Value in the
Guaranteed Interest Account with Market Value Adjustment. (See "Guaranteed
Interest Account with Market Value Adjustment -- Surrenders" and the prospectus
for the Guaranteed Interest Account with Market Value Adjustment which
accompanies this prospectus for further details.)

TAXES

Currently, no charge will be made against MONY America Variable Account A for
federal income taxes. However, the Company may make such a charge in the future
if income or gains within MONY America Variable Account A will incur any
federal income tax liability. Charges for other taxes, if any, attributable to
MONY America Variable Account A may also be made. (See "Federal tax status".)

INVESTMENT ADVISORY FEE

Each portfolio in which the MONY America Variable Account A invests incurs
certain fees and charges. To pay for these fees and charges, the portfolio
makes deductions from its assets. Certain portfolios available under the
Contract in turn invest in shares of other portfolios of AXA Premier VIP Trust
and EQ Advisors Trust and/or shares of unaffiliated portfolios (collectively
the "underlying portfolios"). The underlying portfolios each have their own
fees and expenses, including management fees, operating expenses, and
investment related expenses such as brokerage commissions. The portfolio
expenses are described more fully in each Fund prospectus.

We sell the Contracts through registered representatives of broker-dealers.
These registered representatives are also appointed and licensed as insurance
agents of the Company. We pay commissions to the broker-dealers for selling the
Contracts. You do not directly pay these commissions, we do. We intend to
recover commissions, marketing, administrative and other expenses and the cost
of Contract benefits through the fees and charges imposed under the Contracts.
(See "Distribution of the Contracts" for more information.)



                                                      CHARGES AND DEDUCTIONS  32





10. ANNUITY PROVISIONS



--------------------------------------------------------------------------------

ANNUITY PAYMENTS

Annuity payments under a Contract will begin on the date that is selected by
the Owner when the Contract is applied for. The date chosen for the start of
annuity payments may be:

(1)  no earlier than the 10th Contract Anniversary, and

(2)  no later than the Contract Anniversary after the Annuitant's 95th birthday.

The minimum number of years from the Effective Date to the start of annuity
payments is 10. The date when annuity payments start may be:

(1)  Advanced to a date that is not earlier than the 10th Contract Anniversary.

(2)  Deferred from time to time by the Owner by written notice to the Company.

The date when annuity payments start will be advanced or deferred if:

(1)  Notice of the advance or deferral is received by the Company prior to the
     current date for the start of annuity payments.

(2)  The new start date for annuity payments is a date which is not later than
     the Contract Anniversary after the Annuitant's 95th birthday.

A particular retirement plan may contain other restrictions.

When annuity payments begin, unless Settlement Option 3 or 3A is elected, the
Contract's Cash Value, less any tax charge which may be imposed, will be
applied to provide an annuity or any other option previously chosen by the
Owner and permitted by the Company. If Settlement Option 3 or 3A is elected,
the Contract's Fund Value (less any state taxes imposed when annuity payments
begin) will be applied to provide an annuity.

A supplementary contract will be issued when proceeds are applied to a
settlement option. That contract will describe the terms of the settlement. No
payments may be requested under the Contract's surrender provisions after
annuity payments start. No surrender will be permitted except as may be
available under the settlement option elected.

For Contracts issued in connection with retirement plans, reference should be
made to the terms of the particular retirement plan for any limitations or
restrictions on when annuity payments start.

ELECTION AND CHANGE OF SETTLEMENT OPTION

During the lifetime of the Annuitant and prior to the start of annuity
payments, the Owner may elect:

o   one or more of the settlement options described below, or

o   another settlement option as may be agreed to by the Company.

The Owner may also change any election if written notice of the change is
received by the Company at its Operation Center prior to the start of annuity
payments. If no election is in effect when annuity payments start, a lump sum
payment will be considered to have been elected. For contracts issued in the
State of Texas, if no election is in effect when annuity payments start,
Settlement Option 3 with a period certain of 10 years will be considered to
have been elected.

Settlement options may also be elected by the Owner or the Beneficiary as
provided in the "Death benefit" and "Surrenders" sections of this prospectus.
(See "Death benefit" and "Surrenders").


Where applicable, reference should be made to the terms of a particular
retirement plan and any applicable legislation for any limitations or
restrictions on the options that may be elected.

SETTLEMENT OPTIONS

Proceeds settled under the settlement options listed below or otherwise
currently available will not participate in the investment experience of the
MONY America Variable Account A. Unless you select Settlement Option 1, the
settlement option may not be changed once payments begin.

SETTLEMENT OPTION 1 -- INTEREST INCOME:  Interest on the proceeds at a rate
(not less than 2.75% per year) set by the Company each year. The Option will
continue until the earlier of the date that the payee dies or the date you
elect another settlement option. Under certain contracts, this option is not
available if the Annuitant is the payee.

SETTLEMENT OPTION 2 -- INCOME FOR SPECIFIED PERIOD:  Fixed monthly payments for
a specified period of time, as elected. The payments may, at the Company's
option, be increased by additional interest each year.

SETTLEMENT OPTION 3 -- SINGLE LIFE INCOME:  Payments for the life of the payee
and for a period certain. The period certain may be (a) 0 years, 10 years, or
20 years, or (b) the period required for the total income payments to equal the
proceeds (refund period certain). The amount of the income will be determined
by the Company on the date the proceeds become payable.

SETTLEMENT OPTION 3A -- JOINT LIFE INCOME:  Payments during the joint lifetime
of the payee and one other person, and during the lifetime of the survivor. The
survivor's monthly income may be equal to either (a) the income payable during
the joint lifetime or (b) two-thirds of that income. If a person for whom this
option is chosen dies before the first monthly payment is made, the survivor
will receive proceeds instead under Settlement Option 3, with 10 years certain.


SETTLEMENT OPTION 4 -- INCOME OF SPECIFIED AMOUNT:  Income, of an amount
chosen, for as long as the proceeds and interest last. The amount chosen to be
received as income in each year may not be less than 10 percent of the proceeds
settled. Interest will be credited annually on the amount remaining unpaid at a
rate determined annually by the Company. This rate will not be less than 2.75%
per year.

The Contract contains annuity payment rates for Settlement Options 3 and 3A
described in this prospectus. The rates show, for each $1,000 applied, the
dollar amount of the monthly fixed annuity payment, when this payment is based
on minimum guaranteed interest as described in the Contract.


The annuity payment rates may vary according to the Settlement Option elected
and the age of the payee. The mortality table used in determining the annuity
payment rates for Settlement Options 3 and


33  ANNUITY PROVISIONS





3A is the 1983 Table "a" (discrete functions, without projections for future
mortality), with 3.50% interest per year.

Under Settlement Option 3, if income based on the period certain elected is the
same as the income provided by another available period or periods certain, the
Company will consider the election to have been made of the longest period
certain.

In Qualified Plans, settlement options available to Owners may be restricted by
the terms of the plans.

FREQUENCY OF ANNUITY PAYMENTS

At the time the settlement option is chosen, the payee may request that it be
paid:

o   Quarterly:

o   Semiannually: or

o   Annually

If the payee does not request a particular installment payment schedule, the
payments will be made in monthly installments. However, if the net amount
available to apply under any settlement option is less than $1,000, the Company
has the right to pay such amount in one lump sum. In addition, if the payments
provided for would be less than $25, the Company shall have the right to change
the frequency of the payments to result in payments of at least $25.

ADDITIONAL PROVISIONS

The Company may require proof of the age of the Annuitant before making any
life annuity payment under the Contract. If the Annuitant's age has been
misstated, the amount payable will be the amount that would have been provided
under the settlement option at the correct age. Once life income payments
begin, any underpayments will be made up in one sum with the next annuity
payment. Overpayments will be deducted from the future annuity payments until
the total is repaid.

For contracts issued in the State of Washington, any underpayment by the
Company will be paid in a single sum after the correction of the misstatement.

The Contract may be required to be returned upon any settlement. Prior to any
settlement of a death claim, proof of the Annuitant's death must be submitted
to the Company.

Where any benefits under the Contract are contingent upon the recipient's being
alive on a given date, the Company requires proof satisfactory to it that such
condition has been met.

The Contracts described in this prospectus contain annuity payment rates that
distinguish between men and women. On July 6, 1983, the Supreme Court held in
Arizona Governing Committee v. Norris that optional annuity benefits provided
under an employer's deferred compensation plan could not, under Title VII of
the Civil Rights Act of 1964, vary between men and women on the basis of sex.
Because of this decision, the annuity payment rates that apply to Contracts
purchased under an employment-related insurance or benefit program may in some
cases not vary on the basis of the Annuitant's sex. Unisex rates to be provided
by the Company will apply for Qualified Plans.

Employers and employee organizations should consider, in consultation with
legal counsel, the impact of Norris , and Title VII, generally and any
comparable state laws that may apply, on any employment-related plan for which
a Contract may be purchased.

The Contract is incontestable from its date of issue.

GUARANTEED INTEREST ACCOUNT AT ANNUITIZATION

On the Annuity Starting Date, the Contract's Cash Value, including the Cash
Value of all Accumulation Periods of the Guaranteed Interest Account with
Market Value Adjustment, will be applied to provide an annuity or any other
option previously chosen by the Owner and permitted by the Company. No Market
Value Adjustment will apply at annuitization if the owner elects Settlement
Option 3 or 3A. For more information about annuitization and annuity options,
please refer to the Contract.


                                                          ANNUITY PROVISIONS  34





11. OTHER PROVISIONS



--------------------------------------------------------------------------------

OWNERSHIP

The Owner has all rights and may receive all benefits under the Contract.
During the lifetime of the Annuitant (and Secondary Annuitant if one has been
named), the Owner is the person so designated in the application, unless:

(1)    a change in Owner is requested, or

(2)    a Successor Owner becomes the Owner.

The Owner may name a Successor Owner or a new Owner at any time. If the Owner
dies, the Successor Owner, if living, becomes the Owner. Any request for change
must be:

(1)    made in writing, and

(2)    received at the Company.

The change will become effective as of the date the written request is signed.
A new choice of Owner or Successor Owner will apply to any payment made or
action taken by the Company after the request for the change is received.
Owners should consult a competent tax adviser prior to changing Owners.
--------------------------------------------------------------------------------
SUCCESSOR OWNER -- The living person who, at the death of the Owner, becomes
the new Owner.
--------------------------------------------------------------------------------
PROVISION REQUIRED BY SECTION 72(S) OF THE CODE


The entire interest under a Non-Qualified Contract must be distributed within
five years after the Owner's death if:

(1)  the Owner dies

     (a)    before the start of annuity payments, and

     (b)    while the Annuitant is living; and

(2)  that Owner's spouse is not the Successor Owner as of the date of the
     Owner's death.

Satisfactory proof of death must be provided to the Company.


Spousal status is determined under federal law for this purpose.


The surrender proceeds may be paid over the life of the Successor Owner if:

(1)  the Successor Owner is the Beneficiary, and

(2)  the Successor Owner chooses that option.

Payments must begin no later than one year after the date of death. If the
Successor Owner is a surviving spouse, then the surviving spouse will be
treated as the new Owner of the Contract. Under such circumstances, it is not
necessary to surrender the Contract.

However, under the terms of the Contract, if the spouse is not the Successor
Owner:

(1)  the Contract will be surrendered as of the date of death, and

(2)  the proceeds will be paid to the Beneficiary.

This provision shall not extend the term of the Contract beyond the date when
death proceeds become payable.

If the Owner dies on or after annuity payments start, any remaining portion of
the proceeds will be distributed using a method that is at least as quick as
the one used as of the date of the Owner's death.

PROVISION REQUIRED BY SECTION 401(A)(9) OF THE CODE

The entire interest of a Qualified Plan participant in the Contract generally
will begin to be distributed no later than the required beginning date. For
this purpose "Qualified Plans" include those intended to qualify under Sections
401 and 408 of the Code. Distribution will occur either by or beginning not
later than April 1 of the calendar year following the calendar year the
Qualified Plan Participant attains age 70-1/2. The interest is distributed:

(1)  over the life of such Participant, or

(2)  the lives of such Participant and designated Beneficiary.

If (i) required minimum distributions have begun, and (ii) the Participant dies
before the Owner's entire interest has been distributed to him/her, the
remaining distributions will be made using a method that is at least as rapid
as that used as of the date of the Participant's death.

The Contract generally will be surrendered as of the Participant's death if:

(1)  the Participant dies before the start of such distributions, and

(2)  there is no designated Beneficiary.

The surrender proceeds generally must be distributed within 5 years after the
date of death. But, the surrender proceeds may be paid over the life of any
designated Beneficiary at his/her option. In such case, distributions will
begin not later than one year after the December 31 following the Participant's
death. If the designated Beneficiary is the surviving spouse (as defined by
federal law) of the Participant, distributions will begin not earlier than the
December 31 following the date on which the Participant would have attained age
70-1/2. If the surviving spouse dies before distributions to him/her begin, the
provisions of this paragraph shall be applied as if the surviving spouse were
the Participant. If the Plan is an IRA under Section 408 of the Code, the
surviving spouse may elect to forgo distribution and treat the IRA as his/her
own plan. Although the lifetime required minimum distribution rules do not
apply to Roth IRAs under Section 408A of the Code, the post-death distribution
rules apply.

It is the Owner's responsibility to assure that distribution rules imposed by
the Code will be met. The Owner should consider the effect of recent revisions
to the distribution rules which could increase the minimum distribution amount
required from annuity contracts funding Qualified Plans where certain
additional benefits are purchased under the Contract, such as enhanced death
benefits. For this purpose additional annuity contract benefits may include,
but are not limited to, guaranteed minimum income benefits and enhanced death
benefits. The Owner may want to consult a tax advisor concerning the potential
application of these complex rules before purchasing this annuity Contract or
purchasing additional features under this annuity Contract or making additional
Purchase Payments under this annuity Contract.


35  OTHER PROVISIONS





SECONDARY ANNUITANT

Except where the Contract is issued in connection with a Qualified Plan, a
Secondary Annuitant may be designated by the Owner. Such designation may be
made once before annuity payments begin, either:

(1)  in the application for the Contract, or

(2)  after the Contract is issued, by written notice to the Company at its
     Operations Center.

The Secondary Annuitant may be deleted by written notice to the Company at its
Operations Center. A designation or deletion of a Secondary Annuitant will take
effect as of the date the written election was signed. The Company, however,
must first accept and record the change at its Operations Center. The change
will be subject to:

(1)  any payment made by the Company, or

(2)  action taken by the Company before the receipt of the notice at the
     Company's Operations Center.

You cannot change the Secondary Annuitant, but you can delete the Secondary
Annuitant.

The Secondary Annuitant will be deleted from the Contract automatically by the
Company as of the Contract Anniversary following the Secondary Annuitant's 95th
birthday.

On the death of the Annuitant, the Secondary Annuitant will become the
Annuitant, under the following conditions:

(1)  the death of the Annuitant must have occurred before the Annuity starting
     date;

(2)  the Secondary Annuitant is living on the date of the Annuitant's death;

(3)  if the Annuitant was the Owner on the date of death, the Successor Owner
     must have been the Annuitant's spouse (as defined by federal law); and

(4)  if the date annuity payments start is later than the Contract Anniversary
     nearest the Secondary Annuitant's 95th birthday, the date annuity payments
     start will be automatically advanced to that Contract Anniversary.


EFFECT OF SECONDARY ANNUITANT'S BECOMING THE ANNUITANT.  If the Secondary
Annuitant becomes the Annuitant, the Death Benefit proceeds will be paid to the
Beneficiary only on the death of the Secondary Annuitant. If the Secondary
Annuitant was the Beneficiary on the Annuitant's death, the Beneficiary will be
automatically changed to the person who was the successor Beneficiary on the
date of death. If there was no successor Beneficiary, then the Secondary
Annuitant's executors or administrators, unless the Owner directed otherwise,
will become the Beneficiary. All other rights and benefits under the Contract
will continue in effect during the lifetime of the Secondary Annuitant as if
the Secondary Annuitant were the Annuitant.


ASSIGNMENT

The Owner may assign the Contract. However, the Company will not be bound by
any assignment until the assignment (or a copy) is received by the Company at
its Administrative Office. The Company is not responsible for determining the
validity or effect of any assignment. The Company shall not be liable for any
payment or other settlement made by the Company before receipt of the
assignment.

If the Contract is issued under certain retirement plans, then it may not be
assigned, pledged or otherwise transferred except under conditions allowed
under applicable law.

Because an assignment may be a taxable event, a Owner should consult a
competent tax adviser before assigning the Contract.

CHANGE OF BENEFICIARY

So long as the Contract is in effect the Owner may change the Beneficiary or
successor Beneficiary. A change is made by submitting a written request to the
Company at its Operations Center. The form of the request must be acceptable to
the Company. The Contract need not be returned unless requested by the Company.
The change will take effect as of the date the request is signed. The Company
will not, however, be liable for any payment made or action taken before
receipt and acknowledgement of the request at its Operations Center.

SUBSTITUTION OF SECURITIES

The Company may substitute shares of another mutual fund for shares of the
Funds already purchased or to be purchased in the future by Contract Purchase
Payments if:

(1)  the shares of any portfolio of the Funds is no longer available for
     investment by MONY America Variable Account A, or

(2)  in the judgment of the Company's Board of Directors, further investment in
     shares of one or more of the portfolios of the Funds is inappropriate based
     on the purposes of the Contract.

The new portfolios may have higher fees and charges than the ones they
replaced, and not all portfolios may be available to all classes of contracts.
We will notify you before we substitute securities in any subaccount, and, to
the extent required by law, we will obtain prior approval from the Securities
and Exchange Commission and the Arizona Insurance Department. We also will
obtain any other required approvals (See "Who is MONY Life Insurance Company of
America -- MONY America Variable Account A" for more information about changes
we may make to the subaccounts).

CHANGES TO CONTRACTS

The Company reserves the right, subject to compliance with laws that apply, to
unilaterally change your Contract in order to comply with any applicable laws
and regulations, including but not limited to changes in the Internal Revenue
Code, in Treasury regulations or in published rulings of the Internal Revenue
Service, ERISA and in Department of Labor regulations.

Any change in the Contract must be in writing and made by our authorized
officer. We will provide notice of any contract change.

CHANGE IN OPERATION OF MONY AMERICA VARIABLE ACCOUNT A

MONY America Variable Account A may be operated as a management company under
the 1940 Act or it may be deregistered under the 1940 Act in the event the
registration is no longer required, or MONY America Variable Account A may be
combined with any of other subaccounts.

Deregistration of MONY America Variable Account A requires an order by the
Securities and Exchange Commission. If there is a change in the operation of
MONY America Variable Account A under this provision, the Company may make
appropriate endorsement to the Contract to reflect the change and take such
other action as may be necessary and appropriate to effect the change.


                                                            OTHER PROVISIONS  36





12. VOTING RIGHTS



--------------------------------------------------------------------------------

All of the assets held in the subaccounts of MONY America Variable Account A
will be invested in shares of the designated portfolios of the Funds. The
Company is the legal holder of these shares.

To the extent required by law, the Company will vote the shares of each of the
Funds held in MONY America Variable Account A (whether or not attributable to
contract owners).

We will determine the number of votes which you have the right to cast by
applying your percentage interest in a subaccount to the total number of votes
attributable to that subaccount. In determining the number of votes, we will
recognize fractional shares.

We will vote portfolio shares of a class held in a subaccount for which we
received no timely instructions in proportion to the voting instructions which
we received for all contracts participating in that subaccount. We will apply
voting instructions to abstain on any item to be voted on a pro-rata basis to
reduce the number of votes eligible to be cast.

Whenever a Fund calls a shareholder's meeting, each person having a voting
interest in a subaccount will receive proxy voting material, reports, and other
materials relating to the relevant portfolio. Since each Fund may engage in
shared funding, other persons or entities besides the Company may vote Fund
shares.


37  VOTING RIGHTS





13. DISTRIBUTION OF THE CONTRACTS



--------------------------------------------------------------------------------


The Contracts are distributed by both AXA Advisors, LLC ("AXA Advisors") and
AXA Distributors, LLC ("AXA Distributors") (together, the "Distributors"). The
Distributors serve as principal underwriters of MONY America Variable Account
A. The offering of the Contracts is intended to be continuous.

AXA Advisors is an affiliate of the Company, and AXA Distributors is an
indirect wholly owned subsidiary of the Company. The Distributors are under the
common control of AXA Financial, Inc. Their principal business address is 1290
Avenue of the Americas, New York, NY 10104. The Distributors are registered
with the SEC as broker-dealers and are members of the Financial Industry
Regulatory Authority, Inc. ("FINRA" ). Both broker-dealers also act as
distributors for the Company's life and annuity products.

The Contracts are sold by financial professionals of AXA Advisors and its
affiliates. The Contracts are also sold by financial professionals of
unaffiliated broker-dealers that have entered into selling agreements with the
Distributors ("Selling broker-dealers").

The Company pays compensation to both Distributors based on Contracts sold. The
Company may also make additional payments to the Distributors, and the
Distributors may, in turn, make additional payments to certain Selling
broker-dealers. All payments will be in compliance with all applicable FINRA
rules and other laws and regulations.

Although the Company takes into account all of its distribution and other costs
in establishing the level of fees and charges under its Contracts, none of the
compensation paid to the Distributors or the Selling broker-dealers discussed
in this section of the Prospectus are imposed as separate fees or charges under
your Contract. The Company, however, intends to recoup amounts it pays for
distribution and other services through the fees and charges of the Contract
and payments it receives for providing administrative, distribution and other
services to the Portfolios. For information about the fees and charges under
the Contract, see "Summary of the Contract" and "Charges and deductions"
earlier in this prospectus.

COMPENSATION PAID TO THE DISTRIBUTORS.   The Company pays compensation to the
Distributors based on Purchase Payments made on the Contracts sold through the
Distributors ("contribution-based compensation"). The contribution-based
compensation will generally not exceed 6.50% of the total Purchase Payments
made under the Contracts, plus, starting in the second Contract Year, up to
0.25% of the Fund Value of the Contracts ("asset-based compensation"). The
Distributors, in turn, may pay a portion of the compensation received from the
Company to the Distributors financial professional and/or the Selling
broker-dealer making the sale. The compensation paid by the Distributors varies
among financial professionals and among Selling broker-dealers. The
Distributors also pay a portion of the compensation it receives to its
managerial personnel. When a Contract is sold by a Selling broker-dealer, the
Selling broker-dealer, not the Distributors, determines the amount and type of
compensation paid to the Selling broker-dealer's financial professional for the
sale of the Contract. Therefore, you should contact your financial professional
for information about the compensation he or she receives and any related
incentives, as described below.

AXA Advisors also pays its financial professionals and managerial personnel
other types of compensation including service fees, expense allowance payments
and health and retirement benefits. AXA Advisors also pays its financial
professionals, managerial personnel and Selling broker-dealers sales bonuses
(based on selling certain products during specified periods) and persistency
bonuses. AXA Advisors may offer sales incentive programs to financial
professionals and Selling broker-dealers who meet specified production levels
for the sales of both the Company Contracts and Contracts offered by other
companies. These incentives provide non-cash compensation such as stock options
awards and/or stock appreciation rights, expense-paid trips, expense-paid
education seminars and merchandise.

The Company also pays AXA Distributors compensation to cover its operating
expenses and marketing services under the terms of the Company's distribution
agreements with AXA Distributors.

DIFFERENTIAL COMPENSATION PAID BY AXA ADVISORS.  In an effort to promote the
sale of the Company's products, AXA Advisors may pay its financial
professionals and managerial personnel a greater percentage of
contribution-based compensation and/or asset-based compensation for the sale of
the Company's Contract than it pays for the sale of a Contract or other
financial product issued by a company other than the Company. This practice is
known as providing "differential compensation." Differential compensation may
involve other forms of compensation to AXA Advisors personnel. Certain
components of the compensation paid to managerial personnel are based on
whether the sales involve the Company's Contracts. Managers earn higher
compensation (and credits toward awards and bonuses) if the financial
professionals they manage sell a higher percentage of the Company's Contracts
than products issued by other companies. Other forms of compensation provided
to its financial professionals include health and retirement benefits, expense
reimbursements, marketing allowances and contribution-based payments, known as
"overrides." For tax reasons, AXA Advisors financial professionals qualify for
health and retirement benefits based solely on their sales of the Company's
Contracts and products sponsored by affiliates.

The fact that AXA Advisors financial professionals receive differential
compensation and additional payments may provide an incentive for those
financial professionals to recommend the Company's Contract over a Contract or
other financial product issued by a company not affiliated with the Company.
However, under applicable rules of FINRA, AXA Advisors financial professionals
may only recommend to you products that they reasonably believe are suitable
for you based on the facts that you have disclosed as to your other security
holdings, financial situation and needs. In making any recommendation,
financial professionals of AXA Advisors may nonetheless face conflicts of
interest because of the differences in compensation from one product category
to another, and because of differences in compensation among products in the
same category. For more information, contact your financial professional.

ADDITIONAL PAYMENTS BY AXA DISTRIBUTORS TO SELLING BROKER-DEALERS.  AXA
Distributors may pay, out of its assets, certain Selling broker-dealers and
other financial intermediaries additional compensation in recognition of
services provided or expenses incurred. AXA Distributors may



                                               DISTRIBUTION OF THE CONTRACTS  38






also pay certain Selling broker-dealers or other financial intermediaries
additional compensation for enhanced marketing opportunities and other services
(commonly referred to as "marketing allowances"). Services for which such
payments are made may include, but are not limited to, the preferred placement
of the Company products on a company and/or product list; sales personnel
training; product training; business reporting; technological support; due
diligence and related costs; advertising, marketing and related services;
conference; and/or other support services, including some that may benefit the
Contract owner. Payments may be based on the aggregate account value
attributable to Contracts sold through a Selling broker-dealer or such payments
may be a fixed amount. AXA Distributors may also make fixed payments to Selling
broker-dealers, for example in connection with the initiation of a new
relationship or the introduction of a new product.

Additionally, as an incentive for the financial professionals of Selling
broker-dealers to promote the sale of the Company products, AXA Distributors
may increase the sales compensation paid to the Selling broker-dealer for a
period of time (commonly referred to as "compensation enhancements").

These additional payments may serve as an incentive for Selling broker-dealers
to promote the sale of the Company Contracts over Contracts and other products
issued by other companies. Not all Selling broker-dealers receive additional
payments, and the payments vary among Selling broker-dealers. The list below
includes the names of Selling broker-dealers that we are aware (as of December
31, 2010) received additional payments. These additional payments ranged from
$127 to $3,689,426. The Company and its affiliates may also have additional
business arrangements with Selling broker-dealers. For more information, ask
your financial professional.

1st Global Capital Corporation
Advantage Capital Corporation
AG Edwards
American General Securities Inc
American Portfolios Financial Services
Ameriprise Financial Services, Inc.
Associated Securities Corp.
Bank of America
BBVA Compass Investment Solutions, Inc.
CCO Investment Services Corp.
Centaurus Financial, Inc.
Colonial Brokerage, Inc.
Comerica Securities
Commonwealth Financial Network
CUSO Financial Services, LP
Essex National Securities Inc
FFP
Financial Network Investment Corporation
First Allied Securities
First Citizens Investor Services
First Tennessee Brokerage, Inc.
FSC Securities Corporation
Geneos Wealth Management, Inc.
H.D. Vest Investment Securities, Inc.
Investment Centers of America/First Dakota Inc.
IFC Holdings Inc. DBA Invest Financial Corporation
Investment Professionals, Inc.
Investors Capital Corporation
Ironstone Securities, Inc
J.P. Turner & Co. LLC
James T. Borello & Co.
Janney Montgomery Scott
Key Investment Sevices, LLC
Lincoln Financial Advisors Corporation
Lincoln Financial Securities Corporation
LPL Financial Corporation
M&T Securities
Merrill Lynch Life Agency
MML Investors Services LLC
Morgan Keegan
Morgan Stanley Smith Barney - Morgan Stanley & Co., Incorporated
Multi-Financial Securities Corporation
National Planning Corporation
Next Financial Group, Inc.
NFP Securities, Inc.
Pension Planners Securities Inc
PNC Investments
Prime Capital Services
PrimeVest Financial Services, Inc.
Oppenheimer & Co. Inc.
Raymond James & Associates Inc
Raymond James Financial Service
RBC Capital Markets Corp.
Robert W Baird
Royal Alliance Associates Inc.
RW Baird - Robert N. Baird & Co. Incorporated
Sage Point Financial, Inc
Securities America, Inc.
SII Investments, Inc.
Sorrento Pacific Financial LLC
Stifel, Nicolaus & Co.
Summit Brokerage Services, Inc
Termed/Gunnallen Financial, Inc.
Termed/Mutual Service Corporation
Transamerica Financial Advisors, Inc.
U.S Bancorp Investments, Inc.
UBS Financial Services, Inc.
United Planners' Financial Service of America
UVEST Financial Services Group, Inc.
Waterstone Financial Group, Inc.
Wells Fargo Advisors Financial Network LLC
Wells Fargo Advisors
Wells Fargo Advisors, LLC
Wells Fargo Investments, LLC
Woodbury Financial Services, Inc.


39  DISTRIBUTION OF THE CONTRACTS





14. FEDERAL TAX STATUS



--------------------------------------------------------------------------------

INTRODUCTION

The Contract described in this prospectus is designed for use in connection
with certain types of Qualified Plans and on a nonqualified basis. The ultimate
effect of federal income taxes on

o    the value of the Contract's Fund Value,

o    annuity payments,

o    death benefit, and

o    economic benefit to the Owner, Annuitant, and the Beneficiary may depend
     upon

o    the type of retirement plan for which the Contract is purchased, and

o    the tax and employment status of the individual concerned.


The following discussion of the treatment of the Contract and of the Company
under the federal income tax laws is general in nature. The discussion is based
on the Company's understanding of current federal income tax laws, and is not
intended as tax advice. These federal income tax laws may change without
notice. We cannot predict whether, when, or how these rules could change. Any
change could affect contracts purchased before the change. Congress may also
consider proposals in the future to comprehensively reform or overhaul the
United States tax and retirement systems, which if enacted, could affect the
tax benefits of a contract. We cannot predict what, if any legislation will
actually be proposed or enacted. Any person considering the purchase of a
contract or making additional Purchase Payments under this Contract should
consult a qualified tax adviser. Additional information of the treatment of the
Contract under federal income tax laws is contained in the Statement of
Additional Information. THE COMPANY DOES NOT MAKE ANY GUARANTEE REGARDING ANY
TAX STATUS, FEDERAL, STATE, OR LOCAL, OF ANY CONTRACT OR ANY TRANSACTION
INVOLVING THE CONTRACT.


TAXATION OF ANNUITIES IN GENERAL

The Contract described in this prospectus is designed for use in connection
with Qualified Plans and on a nonqualified basis. All or a portion of the
contributions to such plans will be used to make Purchase Payments under the
Contract. In general, contributions to Qualified Plans and income earned on
contributions to all plans are tax-deferred until distributed to plan
participants or their beneficiaries. Such tax deferral is not, however,
available for Non-Qualified Contracts if the Owner is other than a natural
person unless the Contract is held as an agent for a natural person. Annuity
payments made under a contract are generally taxable to the Annuitant as
ordinary income except to the extent of:

o    Participant after-tax contributions (in the case of Qualified Plans), or

o    Owner contributions (in the case of Non-Qualified Contracts).

Owners, Annuitants, and Beneficiaries should seek advice from their own tax
advisers about the tax consequences of distributions, withdrawals and payments
under Non-Qualified Contracts and under any Qualified Plan in connection with
which the Contract is purchased. For Qualified Contracts, among other things
individuals should discuss with their tax advisors are the "required minimum
distribution rules" which generally require distributions to be made after age
70-1/2 and after death, including requirements applicable to the calculation of
such required distributions from annuity contracts funding Qualified Plans.

Federal tax law imposes requirements for determining the amount includable in
gross income with respect to distributions not received as an annuity.
Distributions include, but are not limited to, transfers, including gratuitous
transfers, and pledges of the contract both of which are treated the same as
distributions. Distributions from all annuity contracts issued during any
calendar year by the same company (or an affiliate) to the Owner (other than
those issued to qualified retirement plans) in the same year will be treated as
distributed from one annuity contract. The IRS is given power to prescribe
additional rules to prevent avoidance of this rule through serial purchases of
contracts or otherwise. None of these rules affects Qualified Plans.

The Company will withhold and remit to the United States Government and, where
applicable, to state and local governments, part of the taxable portion of each
distribution made under a contract unless the Owner or Annuitant

(1)  provides his or her taxpayer identification number to the Company, and

(2)  notifies the Company that he or she chooses not to have amounts withheld.

Distributions of plan benefits from qualified retirement plans, other than
traditional individual retirement arrangements ("traditional IRAs"), generally
will be subject to mandatory federal income tax withholding unless they are:

(1)  Part of a series of substantially equal periodic payments (at least
     annually) for

     (a)  the participant's life or life expectancy,

     (b)  the joint lives or life expectancies of the participant and his/ her
          beneficiary,

     (c)  or a period certain of not less than 10 years;

(2)  Required minimum distributions; or

(3)  Qualifying hardship distributions.

The withholding can be avoided if the participant's interest is directly rolled
over by the old plan to another eligible retirement plan, including an IRA. A
direct rollover transfer to the new plan can be made only in accordance with
the terms of the old plan.

The Company may be liable for payment of the generation skipping transfer tax
under certain circumstances. In the event that the Company determines that such
liability exists, an amount necessary to pay the generation skipping transfer
tax may be subtracted from the death benefit proceeds.


                                                          FEDERAL TAX STATUS  40





RETIREMENT PLANS

Aside from Contracts purchased on a non-qualified basis the Contract described
in this prospectus currently is designed for use with the following types of
retirement plans:

(1)  Pension and Profit Sharing Plans established by business employers and
     certain associations, as permitted by Sections 401(a) and 401(k) of the
     Code, including those purchasers who would have been covered under the
     rules governing H.R. 10 (Keogh) Plans;

(2)  Individual Retirement Annuities permitted by Section 408(b) of the Code,
     including Simplified Employee Pensions established by employers pursuant to
     Section 408(k);

(3)  Roth IRAs permitted by Section 408A of the Code; and

(4)  Deferred compensation plans provided by certain governmental entities and
     tax-exempt organizations under Section 457.

The tax rules applicable to participants in such retirement plans vary
according to the type of plan and its terms and conditions. Therefore, no
attempt is made here to provide more than general information about the use of
the Contract with the various types of retirement plans. Participants in such
plans as well as Owners, Annuitants, and Beneficiaries are cautioned that the
rights of any person to any benefits under these plans are subject to the terms
and conditions of the plans themselves, regardless of the terms and conditions
of the Contract. The Company will provide purchasers of Contracts used in
connection with Individual Retirement Annuities with such supplementary
information as may be required by the Internal Revenue Service or other
appropriate agency. Any person contemplating the purchase of a Contract should
consult a qualified tax adviser.

TAX TREATMENT OF THE COMPANY

Under existing federal income tax laws, the income of MONY America Variable
Account A, to the extent that it is applied to increase reserves under the
Contract, is substantially nontaxable to the Company.


41  FEDERAL TAX STATUS





15. ADDITIONAL INFORMATION AND INCORPORATION OF CERTAIN INFORMATION BY
REFERENCE


--------------------------------------------------------------------------------


The Company's Annual Report on Form 10-K for the period ended December 31, 2010
(the "Annual Report") is considered to be part of this prospectus because it is
incorporated by reference.

The Company files reports and other information with the SEC, as required by
law. You may read and copy this information at the SEC's public reference
facilities at Room 1580, 100 F Street, NE, Washington, DC 20549, or by
accessing the SEC's website at www.sec.gov. The public may obtain information
on the operation of the Public Reference Room by calling the SEC at
1-800-SEC-0330. Under the Securities Act of 1933, The Company has filed with
the SEC a registration statement relating to the Guaranteed Interest Account
with Market Value Adjustment (the "Registration Statement"). This prospectus
has been filed as part of the Registration Statement and does not contain all
of the information set forth in the Registration Statement.


After the date of this prospectus and before we terminate the offering of the
securities under the Registration Statement, all documents or reports we file
with the SEC under the Securities Exchange Act of 1934 ("Exchange Act"), will
be considered to become part of this prospectus because they are incorporated
by reference.

Any statement contained in a document that is or becomes part of this
prospectus, will be considered changed or replaced for purposes of this
prospectus if a statement contained in this prospectus changes or is replaced.
Any statement that is considered to be a part of this prospectus because of its
incorporation will be considered changed or replaced for the purpose of this
prospectus if a statement contained in any other subsequently filed document
that is considered to be part of this prospectus changes or replaces that
statement. After that, only the statement that is changed or replaced will be
considered to be part of this prospectus.

We file the Registration Statement and our Exchange Act documents and reports,
including our Annual Report on Form 10-K and Quarterly Reports on Form 10-Q,
electronically according to EDGAR under CIK No. 0000835357. The SEC maintains a
website that contains reports, proxy and information statements, and other
information regarding registrants that file electronically with the SEC. The
address of the site is www.sec.gov.

Upon written or oral request, we will provide, free of charge, to each person
to whom this prospectus is delivered, a copy of any or all of the documents
considered to be part of this prospectus because they are incorporated herein.
In accordance with SEC rules, we will provide copies of any exhibits
specifically incorporated by reference into the text of the Exchange Act
reports (but not any other exhibits). Requests for documents should be directed
to MONY Life Insurance Company of America, 1290 Avenue of the Americas, New
York, New York 10104. Attention: Corporate Secretary (telephone: (212)
554-1234). You can access our website at www.axa-equitable.com.


 ADDITIONAL INFORMATION AND INCORPORATION OF CERTAIN INFORMATION BY REFERENCE 42





16. LEGAL PROCEEDINGS



--------------------------------------------------------------------------------

MONY Life Insurance Company of America and its affiliates are parties to
various legal proceedings. In our view, none of these proceedings would be
considered material with respect to an Owner's interest in MONY America
Variable Account A, nor would any of these proceedings be likely to have a
material adverse effect upon MONY America Variable Account A, our ability to
meet our obligations under the contracts, or the distribution of the contracts.



43  LEGAL PROCEEDINGS





17. FINANCIAL STATEMENTS



--------------------------------------------------------------------------------


The audited financial statements of MONY America Variable Account A and the
Company are set forth in the Statement of Additional Information. These
financial statements have been audited by PricewaterhouseCoopers LLP, an
independent registered public accounting firm.

The financial statements of the Company should be considered only as bearing
upon the ability of the Company to meet its obligations under the Contracts. You
should not consider the financial statements of the Company as affecting
investment performance of assets in the Variable Account. PricewaterhouseCoopers
LLP also provides independent audit services and certain other non-audit
services to the Company as permitted by the applicable SEC independence rules,
and as disclosed in the Company's Form 10-K. PricewaterhouseCoopers LLP's
address is 300 Madison Avenue, New York, New York 10017.

ABOUT THE GENERAL ACCOUNT

This Contract was offered to customers through various financial institutions,
brokerage firms and their affiliate insurance agencies. No financial
institution, brokerage firm or insurance agency has any liability with respect
to a Contract's account value or any guaranteed benefits with which the
Contract was issued. The Company is solely responsible to the Contract owner
for the Contract's account value and such guaranteed benefits. The general
obligations and any guaranteed benefits under the contract are supported by the
Company's general account and are subject to the Company's claims paying
ability. An owner should look to the financial strength of the Company for its
claims-paying ability. Assets in the general account are not segregated for the
exclusive benefit of any particular Contract or obligation. General account
assets are also available to the insurer's general creditors and the conduct of
its routine business activities, such as the payment of salaries, rent and
other ordinary business expenses. For more information about the Company's
financial strength, you may review its financial statements and/or check its
current rating with one or more of the independent sources that rate insurance
companies for their financial strength and stability. Such ratings are subject
to change and have no bearing on the performance of the variable investment
options. You may also speak with your financial representative.

The general account is subject to regulation and supervision by the Insurance
Department of the State of Arizona and to the insurance laws and regulations of
all jurisdictions where we are authorized to do business. Interests under the
contracts in the general account have not been registered and are not required
to be registered under the Securities Act of 1933 because of exemptions and
exclusionary provisions that apply. The general account is not required to
register as an investment company under the Investment Company Act of 1940 and
it is not registered as an investment company under the Investment Company Act
of 1940. The contract is a "covered security" under the federal securities
laws.

We have been advised that the staff of the SEC has not reviewed the portions of
this Prospectus that relate to the general account. The disclosure with regard
to the general account, however, may be subject to certain provisions of the
federal securities laws relating to the accuracy and completeness of statements
made in prospectuses.



                                                        FINANCIAL STATEMENTS  44





Appendix I: Condensed financial information



--------------------------------------------------------------------------------
                     MONY LIFE INSURANCE COMPANY OF AMERICA
                        MONY AMERICA VARIABLE ACCOUNT A
                            ACCUMULATION UNIT VALUES




                                                                         UNIT VALUE
                                                 ----------------------------------------------------------
                                                  DEC. 31,        DEC. 31,         DEC. 31,       DEC. 31,
SUBACCOUNT                                         2010             2009            2008            2007
-----------------------------------------------------------------------------------------------------------
                                                                                      
All Asset Allocation                               $10.57           $9.32          $7.49          $10.90
-----------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                            8.41            7.54           6.00           10.01
-----------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                         10.41            9.84           9.08           10.34
-----------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation                     9.86            9.16           8.11           10.21
-----------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                              9.52            8.78           7.60           10.20
-----------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                         9.03            8.20           6.82           10.13
-----------------------------------------------------------------------------------------------------------
Dreyfus Stock Index                                  9.38            8.27           6.64           10.69
-----------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity                     10.86            9.81           7.63           12.19
-----------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income                    12.46           10.92           9.92           14.85
-----------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible                      6.76            6.07           4.69            8.66
-----------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                         8.61            7.52           5.78            9.69
-----------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                                  12.75           12.18          12.00           13.32
-----------------------------------------------------------------------------------------------------------
EQ/Equity Growth PLUS                               10.85            9.54           7.57           12.85
-----------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions                   13.96           12.91          11.22           13.20
-----------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                        32.00           24.45          17.52           25.61
-----------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond Index               13.60           13.19           --              --
-----------------------------------------------------------------------------------------------------------
EQ/International Growth                             13.16           11.61           8.57           14.55
-----------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income                    12.08           10.40           8.90           14.19
-----------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                                    14.10           11.34           8.41           16.77
-----------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                               13.58           11.23           --              --
-----------------------------------------------------------------------------------------------------------
EQ/Money Market                                     10.63           10.77          10.88           10.77
-----------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                         10.89           10.20           7.97           12.04
-----------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth                    19.29           14.74           9.49           18.21
-----------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                           12.30           12.36          11.60           12.26
-----------------------------------------------------------------------------------------------------------
EQ/Quality Bond PLUS                                15.77           15.05           --              --
-----------------------------------------------------------------------------------------------------------
EQ/T. Rowe Price Growth Stock                        9.51            8.28           5.88           10.32
-----------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                            11.24           10.08           7.71           13.04
-----------------------------------------------------------------------------------------------------------
Fidelity VIP Contrafund(R)                          14.51           12.56           9.38           16.57
-----------------------------------------------------------------------------------------------------------
Franklin Income Securities                          16.67           14.99          11.21           16.15
-----------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities                14.76           12.40          10.71           14.89
-----------------------------------------------------------------------------------------------------------
Janus Aspen Series Balanced Portfolio               15.53           14.52          11.69           14.08
-----------------------------------------------------------------------------------------------------------
Janus Aspen Series Enterprise Portfolio             10.80            8.70           6.09           10.97
-----------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio                  12.61           11.97           8.29           15.05
-----------------------------------------------------------------------------------------------------------
Janus Aspen Series Worldwide Portfolio               9.18            8.03           5.91           10.83
-----------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                       18.13           14.40          10.85           18.99
-----------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities Fund/VA               20.29           17.77          12.93           21.96
-----------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)                    18.11           16.44          14.26           14.57
-----------------------------------------------------------------------------------------------------------



                                                                                  UNIT VALUE
                                                  ------------------------------------------------------------------------
                                                  DEC. 31,    DEC. 31,      DEC. 31,    DEC. 31,    DEC. 31,   DEC. 31,
SUBACCOUNT                                          2006        2005         2004        2003        2002       2001
--------------------------------------------------------------------------------------------------------------------------
                                                                                               
All Asset Allocation                               $10.57        $9.73        $9.37        $8.75       $7.34       $9.44
--------------------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                            --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                          --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation                     --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                              --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                         --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
Dreyfus Stock Index                                 10.30         9.04         8.75         8.01        6.33        8.26
--------------------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity                     12.21        10.24         --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income                    14.51        12.68        12.10        10.41        8.33        9.90
--------------------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible                      7.80         --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                         --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                                  13.06         --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/Equity Growth PLUS                               11.42        10.58         --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions                   12.93        11.69        11.33        10.90        --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                        23.75        20.26        19.68        16.50       12.17       13.59
--------------------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond Index                --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/International Growth                             12.69        10.24         9.18         8.84        6.85        8.61
--------------------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income                    13.86         --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                                     --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                                --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/Money Market                                     10.40        10.07         --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                         10.10         9.49         9.12         8.88        7.69       10.15
--------------------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth                     --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                           11.14        11.25        11.31        10.94       10.50        --
--------------------------------------------------------------------------------------------------------------------------
EQ/Quality Bond PLUS                                 --           --           --           --          --          --
--------------------------------------------------------------------------------------------------------------------------
EQ/T. Rowe Price Growth Stock                        9.75        10.30        10.04         8.96        5.94        8.53
--------------------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                            13.06        11.60        10.79         9.66        7.67       10.50
--------------------------------------------------------------------------------------------------------------------------
Fidelity VIP Contrafund(R)                          14.29        12.98        11.26         9.90        7.81        8.74
--------------------------------------------------------------------------------------------------------------------------
Franklin Income Securities                          15.78        13.53        13.49        12.01        --          --
--------------------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities                15.51        13.42        13.15        12.01        --          --
--------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Balanced Portfolio               12.91        11.82        11.10        10.37        9.21        9.98
--------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Enterprise Portfolio              9.11         8.13         7.33         6.16        4.62        6.50
--------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio                  11.14        10.32         9.27         7.95        6.68        8.03
--------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Worldwide Portfolio              10.02         8.59         8.22         7.95        6.50        8.85
--------------------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                       18.57        17.07        16.08        14.49       11.93       15.92
--------------------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities Fund/VA               20.98        18.12        16.10        13.73        --          --
--------------------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)                    13.46        13.04        14.15        12.97       11.49        --
--------------------------------------------------------------------------------------------------------------------------




I-1 APPENDIX I: CONDENSED FINANCIAL INFORMATION









                                                                         UNIT VALUE
                                                 ----------------------------------------------------------
                                                  DEC. 31,        DEC. 31,         DEC. 31,       DEC. 31,
SUBACCOUNT                                         2010             2009            2008            2007
-----------------------------------------------------------------------------------------------------------
                                                                                      
ProFund VP Bear                                   5.03              6.20             8.71           6.31
-----------------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity               5.23              6.32             4.84           7.92
-----------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                             10.92              9.06             6.35          19.74
-----------------------------------------------------------------------------------------------------------



                                                                                  UNIT VALUE
                                                  ------------------------------------------------------------------------
                                                  DEC. 31,    DEC. 31,      DEC. 31,    DEC. 31,    DEC. 31,   DEC. 31,
SUBACCOUNT                                          2006        2005         2004        2003        2002       2001
--------------------------------------------------------------------------------------------------------------------------
                                                                                             
ProFund VP Bear                                      6.36       6.97         7.16        8.09         --         --
--------------------------------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity                  8.46       7.79         8.57        9.75         --         --
--------------------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                                19.84      16.34        16.14       13.96         --         --
--------------------------------------------------------------------------------------------------------------------------




                                 APPENDIX I: CONDENSED FINANCIAL INFORMATION I-2









                                                                             UNITS OUTSTANDING
                                                    -------------------------------------------------------------------------------
                                                      DEC. 31,        DEC. 31,        DEC. 31,       DEC. 31,       DEC. 31,
SUBACCOUNT                                             2010            2009             2008          2007            2006
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                                      
All Asset Allocation                                2,681,015       3,190,836       3,976,044       5,513,287        7,300,951
-----------------------------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                             125,972         109,441          57,982          23,678             --
-----------------------------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                           221,943         178,106         171,180          25,364             --
-----------------------------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation                      155,794         158,842         191,867          84,997             --
-----------------------------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                               371,177         476,016         592,487         235,127             --
-----------------------------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                          269,294         293,026         202,158          44,505             --
-----------------------------------------------------------------------------------------------------------------------------------
Dreyfus Stock Index                                 1,831,626       2,258,134       3,003,891       4,131,405        5,268,532
-----------------------------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity                       181,943         245,928         378,596         588,447          162,707
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income                      661,133         866,996       1,228,517       1,872,979        2,493,147
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible                       204,371         264,142         305,886         392,763          491,154
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                          277,556         346,955         464,204         704,758             --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                                  1,617,336       2,064,117         770,250       1,462,548        1,907,446
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Equity Growth PLUS                                 814,368       1,015,952       1,340,581       2,049,590        2,697,953
-----------------------------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions                     145,562         181,250         228,727         307,858          355,264
-----------------------------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                        1,525,805       1,863,329       2,470,253       3,497,734        4,619,713
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond                       725,776         946,198            --              --               --
 Index
-----------------------------------------------------------------------------------------------------------------------------------
EQ/International Growth                               566,604         733,386         951,223       1,314,677        1,619,060
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income                      345,304         448,092         673,983       1,137,673        1,582,779
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                                       63,808          72,187         126,854         166,194             --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                                 647,302         822,335            --              --               --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Money Market                                     1,476,653       1,814,818       2,886,956       3,268,106        3,783,141
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                         4,022,399       5,040,656       6,247,168       8,542,516       12,014,014
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth                      284,685         314,142         373,739         616,094             --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                             303,672         462,400         453,559         444,115          607,070
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Quality Bond PLUS                                  678,561         868,263            --              --               --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/T. Rowe Price Growth Stock                       1,517,985       1,837,732       2,322,411       3,097,303        4,266,241
-----------------------------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                            1,877,719       2,301,746       2,986,644       4,058,934        5,288,888
-----------------------------------------------------------------------------------------------------------------------------------
Fidelity VIP Contrafund(R)                          1,814,712       2,228,837       2,979,630       4,309,960        4,132,884
-----------------------------------------------------------------------------------------------------------------------------------
Franklin Income Securities                            407,327         491,997         711,395       1,026,999        1,032,610
-----------------------------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities                  163,952         173,655         246,117         358,103          418,715
-----------------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Balanced Portfolio               1,184,523       1,470,007       1,954,684       2,761,884        3,539,301
-----------------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Enterprise Portfolio             1,131,580       1,419,916       1,722,276       2,242,169        2,826,266
-----------------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio                  1,010,518       1,289,315       1,547,604       1,997,448        2,485,058
-----------------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Worldwide Portfolio              1,206,618       1,502,931       1,795,688       2,357,570        2,964,196
-----------------------------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                         599,656         773,448         997,235       1,431,540        2,003,547
-----------------------------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities Fund/VA                 240,081         329,171         528,621         879,138        1,058,049
-----------------------------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)                      165,708         224,099         311,052         444,312          568,823
-----------------------------------------------------------------------------------------------------------------------------------
ProFund VP Bear                                        54,582          46,231         117,167          38,052           37,753
-----------------------------------------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity                    45,613          71,161          54,450          96,834          195,027
-----------------------------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                                   75,957         120,086          67,276          74,392           93,443
-----------------------------------------------------------------------------------------------------------------------------------



                                                                               UNITS OUTSTANDING
                                                    -------------------------------------------------------------------------------
                                                      DEC. 31,      DEC. 31,       DEC. 31,          DEC. 31,        DEC. 31,
SUBACCOUNT                                             2005           2004          2003              2002             2001
-----------------------------------------------------------------------------------------------------------------------------------
                                                                                                     
All Asset Allocation                                9,232,209       11,109,364      13,202,566      15,109,160      18,385,691
-----------------------------------------------------------------------------------------------------------------------------------
AXA Aggressive Allocation                                --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
AXA Conservative Allocation                              --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
AXA Conservative-Plus Allocation                         --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
AXA Moderate Allocation                                  --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
AXA Moderate-Plus Allocation                             --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
Dreyfus Stock Index                                 6,734,123        8,132,629       9,138,583       9,933,628      10,780,679
-----------------------------------------------------------------------------------------------------------------------------------
EQ/BlackRock Basic Value Equity                       138,603             --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Boston Advisors Equity Income                    3,121,754        3,207,756       2,990,192       3,454,574       3,446,564
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Calvert Socially Responsible                          --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Capital Guardian Research                             --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Core Bond Index                                       --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Equity Growth PLUS                               3,382,866             --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/GAMCO Mergers and Acquisitions                     281,983          226,652         191,335            --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/GAMCO Small Company Value                        6,024,921        7,075,206       7,841,899       8,512,905       8,277,605
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Intermediate Government Bond                          --               --              --              --              --
 Index
-----------------------------------------------------------------------------------------------------------------------------------
EQ/International Growth                             1,680,543        1,911,713       2,103,075       2,031,440       2,239,322
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Lord Abbett Growth and Income                         --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Index                                         --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Mid Cap Value PLUS                                    --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Money Market                                     4,407,396             --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Montag & Caldwell Growth                         6,339,010       16,012,029      18,983,764      19,728,594      22,923,973
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Morgan Stanley Mid Cap Growth                         --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/PIMCO Ultra Short Bond                             800,622          925,861         915,521         593,890            --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/Quality Bond PLUS                                     --               --              --              --              --
-----------------------------------------------------------------------------------------------------------------------------------
EQ/T. Rowe Price Growth Stock                       5,964,804        7,351,694       8,435,080       8,681,637      10,502,862
-----------------------------------------------------------------------------------------------------------------------------------
EQ/UBS Growth and Income                            6,768,008        8,081,277       9,561,842      11,273,375      13,764,821
-----------------------------------------------------------------------------------------------------------------------------------
Fidelity VIP Contrafund(R)                          4,769,384        5,109,618       5,524,076       5,965,404       6,410,695
-----------------------------------------------------------------------------------------------------------------------------------
Franklin Income Securities                            924,609          587,543         241,886            --              --
-----------------------------------------------------------------------------------------------------------------------------------
Franklin Rising Dividends Securities                  347,075          333,759         216,239            --              --
-----------------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Balanced Portfolio               4,375,862        5,057,432       5,892,043       6,980,943       7,262,031
-----------------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Enterprise Portfolio             3,502,925        4,107,171       4,901,662       5,654,695       7,138,296
-----------------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Forty Portfolio                  3,187,808        3,832,050       4,588,875       5,496,952       6,781,107
-----------------------------------------------------------------------------------------------------------------------------------
Janus Aspen Series Worldwide Portfolio              3,890,586        4,838,805       5,937,772       7,157,869       8,403,354
-----------------------------------------------------------------------------------------------------------------------------------
Multimanager Small Cap Growth                       2,557,971        3,066,363       3,596,274       3,994,202       4,211,857
-----------------------------------------------------------------------------------------------------------------------------------
Oppenheimer Global Securities Fund/VA                 995,554          764,151         262,808            --              --
-----------------------------------------------------------------------------------------------------------------------------------
PIMCO VIT Global Bond (Unhedged)                      672,896          649,315         539,620         410,504            --
-----------------------------------------------------------------------------------------------------------------------------------
ProFund VP Bear                                        32,469           28,387          11,301            --              --
-----------------------------------------------------------------------------------------------------------------------------------
ProFund VP Rising Rates Opportunity                   263,771          345,652         205,410            --              --
-----------------------------------------------------------------------------------------------------------------------------------
ProFund VP UltraBull                                  123,690          157,450         125,726            --              --
-----------------------------------------------------------------------------------------------------------------------------------





I-3 APPENDIX I: CONDENSED FINANCIAL INFORMATION






Statement of Additional Information




--------------------------------------------------------------------------------

TABLE OF CONTENTS


MAY 1, 2011




                                                       
                                                          PAGE
Additional information about the Company                     2
About our independent registered public accounting firm      2
Sale of the contracts                                        2
Federal tax status                                           2
Financial statements                                         4



If you would like to receive a copy of the MONY America Variable Account A
Statement of Additional Information, please return this request to:

     MONY Life Insurance Company of America
     Policyholder Services
     100 Madison Street
     Syracuse, New York 13202
     1-800-487-6669

     www.axa-equitable.com.

-
Please send me a copy of the MONY America Variable Account A Statement of
Additional Information.

--------------------------------------------------------------------------------
Name


--------------------------------------------------------------------------------
Address


--------------------------------------------------------------------------------
City                                            State                    Zip



                                                                          MLA-CM