HEMINGER, PEGGY C.
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FROM: Heminger, Peggy C.
SENT: Friday, August 28, 2015 2:37 PM
TO: 'Oh, Min S.' (OHM@SEC.GOV)
CC: Conner, W. Thomas
SUBJECT: First MetLife Investors Insurance Company - Class O (offered on and
after ______, 2015) (File No. 333-205137)
Mr. Oh:
In response to oral comment (C) regarding the initial registration statement on
Form N-4 for the Class O (offered on and after ______, 2015) variable annuity
contracts of First MetLife Investors Insurance Company, which the staff of the
Securities and Exchange Commission provided to us on August 21, 2015, please
find below the first paragraph under the caption, "Managing Your Withdrawals,"
as revised to include clarifying disclosure. Solely for ease of reference in
this email, the new language has been underlined. Please contact Tom Conner
(tconner@reedsmith.com or 202 414 9208) or me with any questions.
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MANAGING YOUR WITHDRAWALS. It is important that you carefully manage
your annual withdrawals. To retain the full guarantees of this rider,
your annual withdrawals (including any withdrawal charge) cannot
exceed the Annual Benefit Payment each Contract Year. In other words,
you should not take Excess Withdrawals. IF YOU DO TAKE AN EXCESS
WITHDRAWAL, WE WILL RECALCULATE THE BENEFIT BASE IN THE SAME
PROPORTION THAT THE WITHDRAWAL (INCLUDING ANY WITHDRAWAL CHARGE)
REDUCES THE ACCOUNT VALUE AND REDUCE THE ANNUAL BENEFIT PAYMENT TO THE
NEW BENEFIT BASE MULTIPLIED BY THE APPLICABLE GLWB WITHDRAWAL RATE. In
addition, you should not take withdrawals of any amount prior to the
Lifetime Withdrawal Age; however, if your contract is issued while the
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Minimum Issue Age is greater than the Lifetime Withdrawal Age,
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withdrawals prior to the Lifetime Withdrawal Age are only possible if
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you die and your spouse is younger than the Lifetime Withdrawal Age
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and continues the contract and the GLWB under Spousal Continuation
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(see "Spousal Continuation" below). IF YOU (OR YOUR SPOUSE AFTER
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SPOUSAL CONTINUATION, IF APPLICABLE) TAKE A WITHDRAWAL PRIOR TO THE
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LIFETIME WITHDRAWAL AGE, WE WILL RECALCULATE THE BENEFIT BASE IN THE
SAME PROPORTION THAT THE WITHDRAWAL (INCLUDING ANY WITHDRAWAL CHARGE)
REDUCES THE ACCOUNT VALUE. THESE REDUCTIONS IN THE BENEFIT BASE CAUSED
BY WITHDRAWALS PRIOR TO THE LIFETIME WITHDRAWAL AGE, AND IN THE
BENEFIT BASE AND THE ANNUAL BENEFIT PAYMENT CAUSED BY EXCESS
WITHDRAWALS, MAY BE SIGNIFICANT. You are still eligible to receive
lifetime payments so long as the Excess Withdrawal or withdrawal prior
to the Lifetime Withdrawal Age did not cause your Account Value to
decline to zero. AN EXCESS WITHDRAWAL (OR ANY WITHDRAWAL PRIOR TO THE
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LIFETIME WITHDRAWAL AGE) THAT REDUCES THE ACCOUNT VALUE TO ZERO WILL
TERMINATE THE CONTRACT AND CAUSE LIFETIME PAYMENTS TO NOT BE
AVAILABLE.
Best regards,
/s/ Peggy C. Heminger
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PEGGY C. HEMINGER
412.288.7204
pheminger@reedsmith.com
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REED SMITH LLP
Reed Smith Centre
225 Fifth Avenue
Pittsburgh, PA 15222
412.288.3131
Fax 412.288.3063
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