SUTHERLAND ASBILL & BRENNAN LLP LETTERHEAD]
1275 Pennsylvania Avenue NW
Washington, D.C. 20004-2415
202.383.0100
fax 202.637.3593
www.sutherland.com
ATLANTA AUSTIN HOUSTON
NEW YORK TALLAHASEE WASHINGTON DC
W. THOMAS CONNER
DIRECT LINE: 202.383.0590
E-mail: thomas.conner@sutherland.com
April 16, 2009
VIA E-MAIL AND 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. 333-158579)
Dear Ms. White:
First MetLife Investors Insurance 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 April 15, 2009 (the "Simple Solutions Registration Statement" ) selective
review in accordance with Securities Act Release No. 6510 (Feb. 15, 1984).
Disclosure in the Simple Solutions Registration Statement is substantially
similar to the disclosure in the current registration statement on Form N-4
(File No. 333-137370) 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 S Registration
Statement").
The attached typeset versions of the prospectus and statement of additional
information are appropriately marked to indicate the differences between the
Simple Solutions Registration Statement and the Class S Registration Statement
(incorporating prospectus supplements through April 15, 2009). The material
differences are as follows:
. The Simple Solutions Registration Statement does not offer any
optional riders. There is a standard death benefit and a Lifetime
Withdrawal Guarantee ("LWG") benefit; however, these features are
automatically part of the product at issue. Unlike the Simple
Solutions Registration Statement, the Class S Registration
Statement offers the following optional riders for an additional
charge: a Guaranteed Minimum Income Benefit ("GMIB") and an LWG.
Alison White, Esq.
April 16, 2009
Page 2
. Unlike the Class S Registration Statement, the LWG benefit in the
Simple Solutions Registration Statement does not have a
compounding rate and there is an additional withdrawal rate band
(4%) that applies depending on the age of the contract owner at
the time that the first withdrawal is taken.
. Unlike the Class S Registration Statement, there are no
investment allocation restrictions with the LWG benefit in the
Simple Solutions Registration Statement.
In addition to the disclosure differences that reflect substantive differences
between the Simple Solutions Registration Statement and the Class S Registration
Statement, certain additional stylistic, editorial, and updating changes have
been made in the Simple Solutions 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.
John M. Richards, Esq.
Lisa Flanagan, Esq.