SecProbe.io

CORRESP
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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

April
18, 2024

VIA
EDGAR TRANSMISSION

U.S.
Securities and Exchange Commission

100
F Street, N.E.

Washington,
DC 20549

 Re: MEMBERS
                                         Life Insurance Company

                                         Registration Statement on Form S-1 for

                                         TruStage™ Horizon II Annuity

    Post-Effective Amendment No. 2 to

Registration Statement on Form S-1, File No. 333-264135

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”) Post-Effective Amendment No. 2 (the “Amendment”) to the Form S-1 registration
statement referenced above (the “Registration Statement”) for certain flexible premium deferred variable and index-linked
annuity contracts (the “Horizon II Contracts”). The Amendment is being filed solely to include current financial information
as well as to update certain other information and is complete.

The
Company represents that the Registration Statement is substantially similar to the initial filing to the registration statement for
the Contracts previously filed on Form S-1 with the Securities and Exchange Commission (the “Commission”) on April 13,
2023 (File No. 333-264135) and declared effective by the Commission staff on May 1, 2023 (the “Prior Registration
Statement”).  The Company represents that the Registration Statement contains an identical statutory prospectus to that
included in its corresponding registration statement on Form N-4. The Company notes updates were made to correspond to Commission
Staff comments on the Company's other products, but that there have been no changes to the terms of the Contracts or any material
changes to disclosure in the prospectus pertaining to the Contracts in the Registration Statement. The Company represents that the
materiality of the changes from the Prior Registration Statement is consistent with the materiality of changes that would otherwise
qualify for filing under paragraph (b) of Rule 485 under the 1933 Act if Form S-1 registration statements were eligible for filing
under Rule 485.

Based
on the aforementioned, the Company respectfully requests that the Commission staff afford the Registration Statement expedited
review.

U.S. Securities and Exchange Commission

April 18, 2024

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. 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.

Requests
for acceleration of the effective date of the Amendment from the Company and principal underwriter of the Contracts, which were
filed on April 18, 2024, request an effective date of May 1, 2024, or as soon thereafter as reasonably practicable. If you have
any questions regarding the Amendment, please contact the undersigned at 608-665-4184.

Sincerely,

/s/Britney
Schnathorst

Britney
Schnathorst

cc:        Mr.
Thomas Bisset