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ANEAL KRISHNAMURTHY
DIRECT LINE: 202.383.0538
Internet: aneal.k@sablaw.com
October 13, 2006
VIA COURIER
Robert S. Lamont
Division of Investment Management
Office of Insurance Products
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
RE: MetLife Investors USA Insurance Company and First MetLife Investors
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Insurance Company
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Dear Mr. Lamont:
On behalf of MetLife Investors USA Insurance Company ("MLI USA"), First
MetLife Investors Insurance Company ("FMLI"), MetLife Investors USA Separate
Account A, and First MetLife Investors Variable Annuity Account One, we have
enclosed courtesy copies of two initial registration statements on Form N-4
filed on October 12, 2006.
MLI USA and FMLI respectfully request that the Staff of the Securities and
Exchange Commission afford the filings selective review in accordance with
Securities Act Release No. 6510 (Feb. 15, 1984). Disclosure in the MLI USA
filing is substantially similar to the disclosure in the registration statement
on Form N-4 (File No. 333-125756). Disclosure in the FMLI filing is
substantially similar to the disclosure in the registration statement on Form
N-4 (File No. 333-125617). We have enclosed courtesy copies of the filings
marked to show differences between the filings and the effective registration
statements that they are substantially similar to.
The filings for MLI USA and FMLI are virtually identical to each other,
apart from the identity of the insurance company and non-material state
differences.
With regard to the GWB III, we note that the marked copies of the filings
have the disclosure marked as new. However, if you will recall, the GWB III
disclosure was submitted for review on July 13, 2005 pursuant to paragraph
(a)(1) of Rule 485 under the Securities Act of 1933 ("1933 Act") and comments
were provided by the Staff (see, File No. 333-54464). With regard to the
Lifetime Withdrawal Guarantee, we note that the marked copies of the filings
also
October 13, 2006
Page 2
have the disclosure marked as new. However, if you will recall, the Lifetime
Withdrawal Guarantee disclosure was submitted for review on February 7, 2006
pursuant to paragraph (a)(1) of Rule 485 under the 1933 Act and comments were
provided by the Staff (see, File No. 333-54464).
Finally, please note that the fee table in each registration statement will
be revised in accordance with your recent comments on the MetLife Investors
Insurance Company of California "Stalking Horses."
If you have any questions or comments, please contact me at (202) 383-0538
or Tom Conner at (202) 383-0590.
Yours truly,
/s/ Aneal Krishnamurthy
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Aneal Krishnamurthy
Enclosures
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