W. THOMAS CONNER
DIRECT LINE: 203.383.0590
Internet: thomas.conner@sutherland.com
July 24, 2008
VIA EDGAR CORRESPONDENCE SUBMISSION
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Ms. Alison White
Division of Investment Management
Office of Insurance Products
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: Registration Statement on Form N-4 for
First MetLife Investors Insurance Company
First MetLife Investors Variable Annuity Account One
(File No. 333-152450)
Dear Ms. White:
First MetLife Investors Insurance Company (the "Company") and its separate
account, First MetLife Investors Variable Annuity Account One respectfully
request that the Staff of the Commission afford the above-captioned registration
statement filed on July 22, 2008 (the "Class XTRA Registration Statement")
selective review in accordance with Securities Act Release No. 6510 (Feb. 15,
1984). Disclosure in the Class XTRA Registration Statement is substantially
similar to the disclosure in the current registration statement on Form N-4
(File No. 333-96777) for certain individual flexible premium deferred variable
annuity contracts issued by First MetLife Investors Insurance Company through
First MetLife Investors Variable Annuity Account One (the "Class XC Registration
Statement").
The typeset versions of the prospectus and statement of additional
information that were sent to you on July 23, 2008 are appropriately marked to
indicate the differences between the Class XTRA Registration Statement and the
Class XC Registration Statement. The material differences between the two are as
follows:
. In the Class XTRA Registration Statement, the Purchase Payment
Credit is an amount equal to 6% of the initial purchase payment
and each subsequent purchase payment. For contracts with purchase
payments of $200,000 or more, the amount of the credit increases
to 7%. In the Class XC Registration Statement, the Purchase
Payment Credit is an amount equal to 5% of the initial purchase
Alison White, Esq.
July 24, 2008
Page 2
payment and each subsequent purchase payment. For contracts with
purchase payments of $1,000,000 or more, the amount of the credit
increases to 6%.
. The withdrawal charges and mortality and expense risk charge
differ between the Class XTRA Registration Statement and the
Class XC Registration Statement.
. The Class XTRA Registration Statement does not offer the LWG I
rider, the GWB I rider, and the GMIB I rider.
. Under the Class XTRA Registration Statement, the annuity date
must be no earlier than the first contract anniversary. Under the
Class XC Registration Statement, the annuity date must be no
earlier than 30 days after contract issue.
. If the Company receives approval from the Commission, it intends
to recapture Purchase Payment Credits applied to the contracts in
certain circumstances under the Class XTRA Registration
Statement. The Company does not currently recapture Purchase
Payment Credits applied to the contracts under the Class XC
Registration Statement.
In addition to the disclosure differences that reflect substantive
differences between the Class XTRA Registration Statement and the Class XC
Registration, certain additional stylistic, editorial, and updating changes have
been made in the Class XTRA Registration Statement. Please note that the
prospectus sections in the Class XTRA Registration Statement relating to the LWG
II and GMIB Plus are only marked because these prospectus sections were included
in a supplement to the Class XC Registration Statement.
If you have any questions or comments, please contact the undersigned at
(202) 383-0590 or Lisa Flanagan at (202) 383-0873.
Sincerely,
/s/ W. Thomas Conner
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W. Thomas Conner
Enclosures
cc: Michele Abate, Esq.
Lisa Flanagan, Esq.