[SUTHERLAND ASBILL & BRENNAN LLP LETTERHEAD]
W. THOMAS CONNER
DIRECT LINE: 202.383.0590
E-mail: thomas.conner@sutherland.com
September 9, 2011
VIA E-MAIL AND EDGAR CORRESPONDENCE TRANSMISSION
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Min S. Oh, Esq.
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549
Re: MetLife Investors USA Insurance Company
MetLife Investors USA Separate Account A
Initial Registration Statement on Form N-4
(File Nos. 333-176374, 811-03365) (Series VA)
Dear Mr. Oh:
On behalf of MetLife Investors USA Insurance Company ("MLI USA") and its
separate account, MetLife Investors USA Separate Account A, we are providing a
response to comment 3.b of the staff of the U.S. Securities and Exchange
Commission provided by letter dated August 26, 2011 in connection with the
above-captioned initial registration statement.
In this regard, MLI USA acknowledges the Commission staff's comment that the
terms listed in the index be defined the first time that they are used in the
prospectus and upper cased or italicized whenever they appear in the
prospectus. MLI USA will review the prospectus, as discussed in telephone
conversations held on September 7 and 9, 2011, to insure that special terms are
defined the first time that they appear in the prospectus, except where a
definition would detract from the readability or clarity of the disclosure, and
will revise the disclosure, as needed to respond to the comment, in the May 1,
2012 post-effective amendment filing for the above-captioned registration
statement.
If you have questions or comments please contact the undersigned at
202.383.0590, or Patrice Pitts at 202.383.0548.
Sincerely,
/s/ W. Thomas Conner
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W. Thomas Conner
cc: Paul Cellupica, Esq.
Marie Swift, Esq.
Michele Abate, Esq.
John Richards, Esq.
Patrice Pitts, Esq.