SecProbe.io

CORRESP
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MEMBERS
Life Insurance Company

  Britney
Schnathorst

  Associate General Counsel

  Office of General Counsel

  Phone:
  608.665.4184

  E-mail:
  Britney.schnathorst@trustage.com

October
18, 2023

VIA EDGAR TRANSMISSION

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington, DC 20549

 Re: MEMBERS
                                            Life Insurance Company

                                            TruStage™ ZoneChoice Annuity

Post-Effective
Amendment 2 to Registration Statement on Form S-1

File
No. 333-271753

Dear
Commissioners:

On
behalf of MEMBERS Life Insurance Company (the “Company”), we are transmitting for filing under the Securities Act of 1933
(the “1933 Act”) a Post-Effective Amendment 2 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 an enhancement to the current Contract.

The
Company represents that the Registration Statement is substantially similar to the Initial registration statement for the Contracts previously
filed on Form S-1 with the Securities and Exchange Commission (the “Commission”) on May 9, 2023 (File No. 333-271753) and
declared effective by the Commission staff on May 15, 2023 (the “Prior Registration Statement”).  Per the Staff’s
request, the Registration Statement contains two prospectuses – one for Contracts Issued on or before May 25, 2023, and one for
Contracts Issued after May 25, 2023. Changes from the Prior Registration Statement include the following:

 • addition
                                            of a -20% buffer for six-year interest terms. The Contract enhancement is set forth in the
                                            prospectus for Contracts Issued after May 25, 2023 and would apply to new Contract Owners
                                            and existing Contract Owners with Contracts Issued after May 25, 2023.

 • changes
                                            to “Annual Free Withdrawal Amount.” This change is set forth in a supplement
                                            to the prospectus for Contracts Issued on or before May 25, 2023 and applies only to existing
                                            Contract Owners with Contracts issued before September 25, 2022.

 The
Registration Statement takes into account the Staff’s comments to the revised disclosures, which were communicated by phone and
email. Based on the aforementioned, the Company respectfully requests that the Commission staff afford the Registration Statement expedited
review.

U.S. Securities and Exchange Commission

October 18, 2023

Page 2

The
Company relies on the permission granted under Regulation S-X §3-13 by the Commission in a letter dated November 6, 2020, to file
audited financial statements of the Company prepared in accordance with statutory accounting principles in place of financial statements
prepared in accordance with accounting principles generally accepted in the United States of America (“GAAP”). The Company
requested permission to use these financial statements in connection with certain registration statements on Form S-1 that are currently
effective or may be filed in the future for index-linked annuity contracts, in satisfaction of the financial information required by
Form S-1, including the requirements of Items 11(e), 11(f) and 11(g) and Item 16(b) of Form S-1.

If
you have questions regarding the Registration Statement, please contact the undersigned at 608-665-4184.

Sincerely,

/s/Britney
Schnathorst

Britney
Schnathorst

  cc:
  Ms. Elisabeth Bentzinger

  Mr. Thomas Bisset