Correspondence 0001753926-23-000607 from MEMBERS Life Insurance Co (CIK 0001562577)
MEMBERS Life Insurance Co (CIK 0001562577)
Date: May 9, 2023 · CIK: 0001562577 · Accession: 0001753926-23-000607
AI Filing Summary & Sentiment
Letter
Office of General Counsel VIA EDGAR TRANSMISSION Division of Investment Management Washington, D.C. 20549 Re: MEMBERS Life Insurance Company TruStage™ ZoneChoice Annuity Initial to Registration Statement on Form S-1
Dear Commissioners:
On behalf of MEMBERS Life Insurance Company (the “Company”), we are providing responses to comments received from the staff (“Staff”) of the Securities and Exchange Commission (the “Commission” or “SEC”). We are transmitting for filing an initial Registration Statement on Form S-1 (the “Registration Statement”) for certain single premium deferred annuity contracts with index-linked interest options (the “Contracts”). The purpose of this filing is to include enhancements to the current Contract under the Securities Act of 1933 (the “1933 Act”).
The Registration Statement will incorporate changes made in response to comments raised by the Staff. For the Staff’s convenience, each comment is set forth in full below, followed by the response. Acceleration requests from the Company and the principal underwriter also accompany the filing.
1. Please provide a white paper or fact sheet for the Dimensional US Small Cap Value Systematic Index.
Response Attached.
2. Please confirm that the index information for the Dimensional US Small Cap Value Systematic Index will be published publicly.
Response: Confirmed.
3. Please confirm that the Dimensional US Small Cap Value Systematic Index is a rules-based index.
Response: Confirmed.
4. Please supplementally provide more detail about the relationship between the index provider and the Registrant, and confirm that the Dimensional US Small Cap Value Systematic Index is not proprietary to the Registrant.
Response: The Dimensional US Small Cap Value Systematic Index is proprietary to Dimensional Fund Advisers, who operate the index. Dimensional Fund Advisers is not an affiliate of the Registrant.
Ms. Bentzinger
May 9, 2023
Page 2
If you have any questions regarding this letter or the Registration Statement, please contact the undersigned at 608-665-4184. We greatly appreciate the Staff’s efforts in assisting the Company with this filing.
Sincerely,
/s/Britney
Schnathorst
Show Raw Text
CORRESP
1
filename1.htm
MEMBERS
Life Insurance Company
Britney
Schnathorst
Associate General Counsel
Office of General Counsel
Phone:
608.665.4184
E-mail:
Britney.schnathorst@cunamutual.com
May
9, 2023
VIA
EDGAR TRANSMISSION
Ms.
Elisabeth Bentzinger, Esq.
Senior Counsel, Disclosure Review Office No. 3
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street, N.E.
Washington, D.C. 20549
Re: MEMBERS
Life Insurance Company
TruStage™ ZoneChoice Annuity
Initial
to Registration Statement on Form S-1
Dear
Commissioners:
On
behalf of MEMBERS Life Insurance Company (the “Company”), we are providing responses to comments received from the staff
(“Staff”) of the Securities and Exchange Commission (the “Commission” or “SEC”). We are transmitting
for filing an initial Registration Statement on Form S-1 (the “Registration Statement”) for certain single premium deferred
annuity contracts with index-linked interest options (the “Contracts”). The purpose of this filing is to include enhancements
to the current Contract under the Securities Act of 1933 (the “1933 Act”).
The
Registration Statement will incorporate changes made in response to comments raised by the Staff. For the Staff’s convenience,
each comment is set forth in full below, followed by the response. Acceleration requests from the Company and the principal underwriter
also accompany the filing.
1. Please
provide a white paper or fact sheet for the Dimensional US Small Cap Value Systematic Index.
Response Attached.
2. Please
confirm that the index information for the Dimensional US Small Cap Value Systematic Index
will be published publicly.
Response: Confirmed.
3. Please
confirm that the Dimensional US Small Cap Value Systematic Index is a rules-based index.
Response: Confirmed.
4. Please
supplementally provide more detail about the relationship between the index provider and
the Registrant, and confirm that the Dimensional US Small Cap Value Systematic Index is not
proprietary to the Registrant.
Response: The
Dimensional US Small Cap Value Systematic Index is proprietary to Dimensional Fund Advisers,
who operate the index. Dimensional Fund Advisers is not an affiliate of the Registrant.
Ms. Bentzinger
May 9, 2023
Page 2
If
you have any questions regarding this letter or the Registration Statement, please contact the undersigned at 608-665-4184. We greatly
appreciate the Staff’s efforts in assisting the Company with this filing.
Sincerely,
/s/Britney
Schnathorst
Britney
Schnathorst
cc:
Ms.
Elisabeth Bentzinger
Mr.
Thomas Bisset
Attachment