[Logo of EVERSHEDS SUTHERLAND] EVERSHEDS SUTHERLAND (US) LLP 1114 Avenue of the Americas, 40th Floor New York, NY 10036-7703 D: +1 212.389.5080 F: +1 212.389.5099 dodiekent@ eversheds-sutherland.com April 6, 2018 VIA EDGAR TRANSMISSION ---------------------- U.S. Securities and Exchange Commission 100 F Street, NE Washington, DC 20549 RE: BRIGHTHOUSE LIFE INSURANCE COMPANY (THE "COMPANY") REGISTERED FIXED ACCOUNT OPTION CONTRACT PRE-EFFECTIVE AMENDMENT NO. 1 TO THE REGISTRATION STATEMENT FILED ON FORM S-3 (FILE NO. 333-221620) FIXED ANNUITY (STRATEGIC VALUE ANNUITY) CONTRACT PRE-EFFECTIVE AMENDMENT NO. 1 TO THE REGISTRATION STATEMENT FILED ON FORM S-3 (FILE NO. 333-221619) LIQUIDITY BENEFIT CONTRACT PRE-EFFECTIVE AMENDMENT NO. 1 TO THE REGISTRATION STATEMENT FILED ON FORM S-3 (FILE NO. 333-221618) Dear Commissioners: The Company is transmitting for filing under the Securities Act of 1933, as amended, the pre-effective amendments to the above-referenced registration statements (the "Registration Statements"). The Registration Statements were originally filed on November 16, 2017. Through written correspondence filed with the Commission on March 5, 2018, the Company responded to the written comments provided by the Commission's Staff in a letter dated January 12, 2018. The Registration Statements have been revised in accordance with the Company's responses to the Commission Staff's comments and the marked pages provided thereto. The Company is also transmitting for filing written correspondence from the Company and the principal underwriter, Brighthouse Securities, LLC, requesting that the Registration Statements be declared effective by the Commission on April 30, 2018 or as soon as practical thereafter. Please contact the undersigned at the above number if you have any questions or comments regarding this letter, the Registration Statements, or the requests to accelerate effectiveness. Sincerely, /s/ Dodie C. Kent ------------------------------ Dodie C. Kent cc: Michele H. Abate, Brighthouse Financial Ronald Coenen Jr., Eversheds Sutherland Eversheds Sutherland (US) LLP is part of a global legal practice, operating through various separate and distinct legal entities, under Eversheds Sutherland. For a full description of the structure and a list of offices, please visit www.eversheds-sutherland.com.