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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
19, 2024

VIA
EDGAR

Ms.
Ellie Quarles, Esq.

Division of Investment Management

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

    Re:
    MEMBERS
    Life Insurance Company

    MEMBERS Zone Annuity

    Initial Registration Statement on Form S-1

    File Nos. 333-276341

Dear
Ms. Quarles:

On
behalf of MEMBERS Life Insurance Company (the “Company”), we are providing responses to oral comments received from
the staff (“Staff”) of the Securities and Exchange Commission (the “Commission” or “SEC”)
by our counsel on the above-referenced Form S-1 Registration Statement (“Registration Statement”). The Staff provided
initial comments by telephone on March 5, 2024, and follow up comments and proposed responses and revisions were subsequently
communicated between the Staff and the Company via telephone and email. We are transmitting this response letter in anticipation
of filing with the Commission Pre-Effective Amendment No. 1 to the Registration Statement (the “Amendment”) for certain
single premium deferred annuity contracts (the “Contracts”) under the Securities Act of 1933, as amended (the “1933
Act”).

The
Amendment will incorporate changes made in response to comments raised by the Staff and include information necessary to complete
the Registration Statement, such as financial statements. For the Staff’s convenience, each comment is set forth in full
below, followed by the response.

Cover
Page

 1. Retain
                                         the following in the first paragraph or elsewhere in the Prospectus: “This Prospectus
                                         describes all material rights and obligations of Owners, including all state variations.”

 Response: The
                                         Company has made the requested revision.

Ms. Quarles

April 19, 2024

Page 2

 2. Please
                                         revise the second paragraph, third sentence to state as follows: For each Risk Control
                                         Account, we credit interest at the end of the Contract Year based in part on the performance
                                         of the S&P 500 Price Index (the “Index”) by comparing the change in the
                                         Index from each Contract Anniversary (the first day of the Contract Year) to the last
                                         day of the Contract Year, subject to the applicable Index Interest Rate Floor and Index
                                         Interest Rate Cap.

 Response: The
                                         Company has made the requested revisions.

 3. Please
                                         revise the second paragraph, fourth sentence to state as follows: It is possible that
                                         you will not earn any interest in a Risk Control Account or that we may credit negative
                                         interest to the Growth Account.”

 Response: The
Company has made the requested revision.

 4. In
                                         the second paragraph, first
                                         bullet point, final sentence, change “Floor” to “Growth Account”.
                                         At the end of the sentence, change “the applicable Floor” to “-10%
                                         for each crediting period.”

 Response: The
                                         Company has made the requested revisions.

 5. In
                                         addition to the 10% additional tax, add references to federal tax penalties throughout
                                         the document where applicable.

 Response: The
                                         Company has made the requested revisions to define and explain tax penalties. The Company
                                         respectfully submits that the 10% tax on withdrawals taken before Age 59 ½ is
                                         characterized by the Code and the IRS as an “additional tax” and not as a
                                         penalty, and therefore the Company uses that terminology.

Highlights

 6. Under
                                         “How the Contract Works,” in the third paragraph, fifth sentence, change
                                         “Risk Control Accounts” to “Growth Account” and change “Floor”
                                         to “-10%.”

 Response: The
                                         Company has made the requested revisions.

 7. Under
                                         How Your Contract Works - “Allocation
                                         Options,” and in the Allocation Options section, please include a chart showing
                                         the allocation options, similar to the chart that the Company includes in its other product
                                         filings. As a follow up comment to the Company’s draft response, do not include
                                         the sentence about the Initial Index Period within the table. Revise the first footnote
                                         under the table to reflect the changes made in response to Comment No. 2.

 Response: The
                                         Company has made the requested revisions.

 8. Under
                                         How Your Contract Works - “Allocation
                                         Options,” in the fourth sentence, delete the word “currently” and the
                                         phrase “, but may reduce or increase the durations offered from time to time for
                                         new Contracts that we issue.”

 Response: The
                                         Company has made the requested revisions.

 9. Please
                                         advise us if you have any Contracts in the Initial Index Period.

 Response: Yes,
                                         there are currently 26,066 Contracts ranging from one to eight years remaining in the
                                         Initial Index Period.

Ms. Quarles

April 19, 2024

Page 3

 10. Under
                                         How Your Contract Works - Allocation Options, last paragraph, discuss the risk that if
                                         an Index is discontinued, there may be a potential delay in finding a suitable Index
                                         replacement, and that no interest would be credited during that interim period.

 Response: The
Company has made the requested revisions.

 Highlights

 11. Under
                                         How Your Contract Works – Withdrawal Options, at the end of the first sentence,
                                         add “or surrender the Contract.”

 Response: The
Company has made the requested revisions.

 12. Under
                                         How Your Contract Works, move the Market Value Adjustment (MVA) section to the Contract
                                         Charges section, following the Surrender Charges subsection.

 Response: The
Company has made the requested revisions.

 13. Under
                                         Contract Charges – Market Value Adjustment (MVA), revise the final sentence to
                                         read as follows: “You may lose up to XXX% of your principal and previously
                                         credited interest due to the MVA.” (italics to show changes).

 Response: The
Company has made the requested revisions.

 14. Please
                                         consider whether the impact of COVID-19 is still a principal risk, or if this risk disclosure
                                         should be deleted.

 Response: The
Company has deleted the disclosure.

 15. Under
                                         Risk Factors – Risk That We May Eliminate or Substitute an Index, after the fifth
                                         sentence, add: “If there is a delay between the date we remove the Index and the
                                         date we add a substitute Index, your Risk Control Account Value will be based on the
                                         value of the Index on the date the Index ceased to be available, which means market changes
                                         during the delay will not be used to calculate the Credited Index Interest.”

 Response: The
Company has made the requested revisions.

 16. Under
                                         Risk Factors – No Ownership Rights, change “stocks” to “securities”.
                                         Please make this change throughout the document where applicable.

 Response: The
Company has made the requested revisions.

 17. Under
                                         Risk Control Accounts, in the second paragraph, first sentence, change “based on
                                         the percentage change in the interest during the Contract Year just completed”
                                         and add “by comparing the change in the Index from each Contract Anniversary (the
                                         first day of the Contract Year) to the last day of the Contract Year.”

 Response: The
Company has made the requested revisions.

Ms. Quarles

April 19, 2024

Page 4

 18. Under
                                         Risk Control Account – Interest Rate Calculation Methodology, in the second sentence,
                                         change “based on the percentage change in the Index over a Contract Year,”
                                         to “by comparing the Initial Index Value (the index value on Contract Anniversary,
                                         which is the first day of the Contract Year) to the value on the last day of the current
                                         Contract Year.”

 Response: The
Company has made the requested revisions.

 19. Under
                                         Risk Control Account – Growth Account – Addition or Substitution of an Index,
                                         please include a discussion of how the Risk Account Value will be calculated if there
                                         is not an Index.

 Response: The
Company has made the requested revisions.

 20. Under
                                         Market Value Adjustment (“MVA”) – Purpose of the MVA, rewrite the last
                                         sentence as follows: The MVA helps protect us from market losses related to changes
                                         in the value of the fixed income investments and other investments we use to back
                                         the guarantees under your Contract from the date we issue the Contract to the time of
                                         a surrender or partial withdrawal if we have to sell those investments early to pay
                                         the surrender or partial withdrawal. (emphasis added to show revisions).

 Response: The
Company has made the requested revisions.

 21. Move
                                         “Surrender Value” and the first sentence of “Fees and Charges”
                                         that states “We access the following fees under Contracts” to precede the
                                         MVA discussion. Change the “Surrender Charge and MVA” heading to “Surrender
                                         Charge,” and change the MVA section heading so it matches the other subsection
                                         under “Fees and Charges.”

 Response: The
                                         Company has made the requested revisions.

*
*

The Company has responded to all Staff comments and believes that all comments have been resolved. As discussed with the Staff, the Company
is filing the Amendment with the SEC on or about the same date as this letter and requests an effective date on or about May 1, 2024.

If
you have any questions regarding this letter or the Amendment, 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:
Thomas Bisset