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    Britney Schnathorst

    Associate General Counsel

    Office of General Counsel

    Phone: 608.665.4184

    E-mail: Britney.Schnathorst@trustage.com

    MEMBERS Life Insurance
Company

January 2, 2024

VIA EDGAR TRANSMISSION

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

    Re:

    MEMBERS Life Insurance Company

    MEMBERS® Horizon Flexible Premium Deferred Variable

    and Index Linked Annuity

    Initial Registration Statement on Form S-1

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”)
an initial registration statement on Form S-1 (the “Registration Statement”) for certain Flexible Premium Deferred Variable
and Index Linked Annuity Contracts (the “Contracts”). The Company no longer issues new Contracts. The Registration Statement
is being filed solely for the purpose of replacing the current registration statement for the Contracts which will expire three years
after its effective date pursuant to Rule 415(a)(5) under the 1933 Act.

The Company represents that
the Registration Statement is substantially similar to the Post-Effective Amendment No. 2 to the current registration statement for the
Contracts filed on Form S-1 with the Commission on April 13, 2023 (File No. 333-249535) (the “Prior Registration Statement”)
which the Commission staff made effective on May 1, 2023.  The Company notes that there have been no changes to the terms of the
Contracts. Changes from the Prior Registration Statement include updated disclosure and clarifying changes made to reflect the Staff’s
comments with respect to the Company’s other registered products. The Company plans to forward to the Commission staff a marked
copy of the prospectus to the Registration Statement that highlights changes made from the prospectus to the Prior Registration Statement.

The Company plans to file
a pre-effective amendment to the Registration Statement that will respond to any comments from the Commission staff on the Registration
Statement and that will include financial statements for the Company, exhibits and all other required information.

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 any questions
regarding the Registration Statement, please contact the undersigned at 608-665-4184.

Sincerely,

/s/ Britney Schnathorst

Britney Schnathorst

cc:       Thomas Bisset, Esq.