First MetLife Investors Insurance Company
200 Park Avenue
New York, NY 10166
VIA EDGAR TRANSMISSION
----------------------
December 13, 2011
Min Oh, Esq.
Division of Investment Management
Office of Insurance Products
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549-4644
RE: POST-EFFECTIVE AMENDMENT NO. 3 TO THE REGISTRATION STATEMENT ON FORM N-4
FOR
FIRST METLIFE INVESTORS INSURANCE COMPANY
FIRST METLIFE INVESTORS VARIABLE ANNUITY ACCOUNT ONE
(FILE NOS. 811-08306 AND 333-176680)
Dear Mr. Oh:
First MetLife Investors Insurance Company (the "Company"), on its own behalf and
on behalf of First MetLife Investors Variable Annuity Account One (the "Separate
Account"), provides this letter in response to oral comments provided by the
staff of the U.S. Securities and Exchange Commission ("Commission") on December
5, 2011, with respect to Post-Effective Amendment No. 2 to the Separate
Account's registration statement.
The Company acknowledges that:
. should the Commission or the Commission staff, acting pursuant to
delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the
filing;
. the action of the Commission or the Commission staff, acting pursuant
to delegated authority, in declaring the filing effective, does not
relieve the Company, on behalf of the Separate Account, from its full
responsibility for the adequacy and accuracy of the disclosure in the
filing; and
. the Company, on behalf of the Separate Account, may not assert this
action as a defense in any proceeding initiated by the Commission or
any person under the federal securities laws of the United States.
* * *
If you have any questions or further comments, please call the undersigned at
(212) 578-4951 or Tom Conner at (202) 383-0590.
Sincerely,
/s/ Paul L. LeClair
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Paul L. LeClair
Vice President
cc: W. Thomas Conner, Esq.
Patrice M. Pitts, Esq.
Michele H. Abate, Esq.
John B. Towers, Esq.