HEMINGER, PEGGY C.

FROM:                  Conner, W. Thomas
SENT:                  Thursday, November 06, 2014 1:46 PM
TO:                    Sonny S. Oh (ohm@sec.gov)
CC:                    Heminger, Peggy C.; Conner, W. Thomas
SUBJECT:               FW: Email for Sonny - Revised per Email from Sharon Judge

Sonny:

Thank you for reaching out to me this morning to discuss the application
processing procedures that will be used to issue the MetLife Accumulation
Annuity (MAA) contracts.  After our call yesterday evening, we received the
following additional information.

Importantly, we learned that eligibility for the current PGR fee rate will be
established by receipt of an electronic application from Fidelity.  By way of
background, we understand that no paper applications will be available at the
point of sale.  All the information is taken and keyed electronically into
Annuity Net.  The application is then printed from Annuity Net, signed by both
the registered representative and the client, and then, as is required by FINRA
Rule 2330 for all variable annuity sales, sent electronically (and in hard copy)
to the Fidelity Broker-Dealer Annuity Service Center in Kentucky for suitability
review.  Once it has been approved, the electronic submission comes through to
MetLife through DTCC feeds.  The PGR fee rate is set at the time of receipt by
the MetLife Annuity Service Center of the electronic approved application.

The customer will be provided with a product prospectus and a prospectus
supplement that states the current PGR fee rate and the period during which the
rate is effective.  Met will commit to providing the Fidelity field force with a
new supplement three weeks ahead of any rate change.  Accordingly, the customer,
when he/she completes the application, will know with certainty when they sign
the application that as long as the Fidelity Broker-Dealer Annuity Service
Center reviews, approves, and sends the application electronically to the
MetLife Annuity Service Center by the final day of the current effective fee
rate period, they will get the current fee rate.  FINRA's variable annuity
suitability Rule, Rule 2330, requires a selling firm to conduct a suitability
review and provide principal sign-off before forwarding it to the issuing
insurance company, in all cases within seven days.  We have discussed with
Fidelity obtaining a signed acknowledgement form from the client if the
application date is within the seven day period prior to the end of a fee rate
period.

The paper application and the initial premium payment will typically arrive at
the MetLife Annuity Service Center the day following the date of receipt of the
electronic application, which will start the two-day five-day clock for purposes
of Rule 22c-1(c).  It is possible, of course, as is the case for all annuity
applications, that the application could still be determined not to be in Good
Order, in which case the contract would not be issued.

We believe the process described above should allay the Staff's concerns
regarding the PGR rate setting process.  I understand that you will discuss
these procedures with Bill Kotapish and Joyce Pickholz as soon as practicable.
In the meantime, we will review the MAA prospectus and PGR fee rate advisory
supplement, make revisions as necessary and submit those for the Staff's review
and approval.  I believe you will also need to review the changes we submitted
to conform the MAA prospectus with the MetLife Investment Portfolio Architect
prospectus your colleague Keith Gregory is working on.  If we could square away
these last aspects of the filing today, MetLife and its partner, Fidelity, would
be very pleased.  Lastly, if you could review the MGI revisions and get back to
us on those today, MetLife and Fidelity would be even more pleased.

Thanks again for your assistance on this.

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Best regards,

Tom

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