SEC Division of Investment Management staff letter: MONY Life Insurance Company of America

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SECURITIES AND EXCHANGE COMMISSION
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DIVISION OF
I NVESTMENT MANAGEMENT
March 7, 2019
VIA ELECTRONIC MAIL
RESPONSE OF CHIEF ACCOUNTANT'S OFFICE
DIVISION OF INVESTMENT MANAGEMENT
Stephen E. Roth
Dodie C. Kent
Eversheds Sutherland (US) LLP
Email: steveroth(a,eversheds-sutherland.com dodiekent(~eversheds-sutherland.com Re: MONY Life Insurance Company of America By letter dated March 7, 2019, you request authority under Regulation S-X §3-13 ("Rule 3-13") for MONY Life Insurance Company of America ("Company") to file audited financial statements of the Company prepared in accordance with statutory accounting principles) ("SAP"), in place of financial statements prepared in accordance with accounting principles generally accepted in the United States of America ("GAAP"), in registration statements filed under the Securities Act of 1933 ("Securities Act") on Form S-1 for market value adjusted fixed account investment options ("MVA Options") that are available under certain variable annuity contracts, as well as for index-linked options ("MSOs") that are available under certain variable life insurance contracts issued by the Company (together with the variable annuity contracts, "Contracts"), in satisfaction of the requirements of Items 11(e), 11(~ and 11(g) and Item 16(b) of Form S-1, as described in your letter. Background The CompanX You state that the Company is a stock life insurance company organized under the laws of the state of Arizona that is authorized to conduct life insurance and annuity business in the District of Columbia, Puerto Rico, the U.S. Virgin Islands and all states except New York. You note that these principles are those that are prescribed or permitted by the Company's domiciliary state regulator.