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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

        TruStage
Zone Income Annuity

Initial Registration Statement on Form S-1

        File
No. 333-276157

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 February 21, 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 modified guaranteed index 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.

General

 1. Please
                                         confirm that all missing information, including information in appendices, the financial
                                         statements, and all exhibits, will be filed in a pre-effective amendment to the registration
                                         statement. We may have further comments when you supply the omitted information.

 Response: Confirmed.

    Ms. Quarles

April 19, 2024

Page 2

 2. Please
                                         clarify supplementally whether there are any types of guarantees or support agreements
                                         with third parties to support any Contract features or benefits, or whether the Company
                                         will be solely responsible for any benefits or features associated with the Contract.

 Response: The
                                         Company is solely responsible for all features and benefits associated with the Contracts.
                                         There are no guarantee or support agreements with third parties that support any benefit
                                         or feature of the Contracts.

 3. Where
                                         a comment is made in one location, please note that it is applicable to all similar disclosure
                                         elsewhere in the registration statement. Further, where disclosure is requested to be
                                         added in one place, please add similar disclosure to all other places where such disclosure
                                         would be relevant. For example, requests for disclosure changes on the cover page should
                                         also be made in the summary, risk factors and elsewhere as appropriate.

 Response: Confirmed.

Cover
Page

 4. On
                                         the cover page and in several other sections, references to six-year terms were removed.
                                         Please clarify when a six-year term will apply and when a one-year term will apply for
                                         the calculation of the Accumulation Credit Factor and if the terms differ for current
                                         investors and new investors. Please make these changes throughout the document.

 Response: For
                                         all investors, one-year terms apply to the various allocation options; in other words,
                                         interest is credited each Contract Year, and on each Contract Anniversary, investors
                                         may reallocate to other options without penalty. Six-year terms are relevant for the
                                         following: (1) Market Value Adjustment calculation (all contracts); (2) guaranteed Interest
                                         Rate for the Declared Rate Account (for Contracts issued before May 25, 2024); (3) Minimum
                                         Interest Rate calculation for the Declared Rate Account (for Contracts issued on or after
                                         May 25, 2024); (4) arbitrarily resetting the Accumulation Credit Factor at $10 (all Contracts);
                                         and (5) the Surrender Charge period (all Contracts). The Company has retained some of
                                         the original language about six-year terms and made revisions to clarify.

 5. In
                                         the second paragraph, please replace “initial Purchase Payment” with “single
                                         Purchase Payment.” The Staff notes that “initial” might imply that
                                         additional purchase payments are permitted. Please make this change throughout the document.

 Response: The
Company has made the requested revisions.

 6. In
                                         the third paragraph, please add the following language that was struck from the amendment:
                                         “All withdrawals under the Contract other than GLWB Payments are Excess Withdrawals
                                         that reduce the Death Benefit, GLWB Benefit Base, and GLWB Payment, perhaps significantly,
                                         and could terminate the Contract.”

In
addition, add language substantially similar to the following, including the bold font as indicated: “The GLWB Payment is
a withdrawal of your own Contract Value unless the Contract Value is reduced to zero. The probability of you outliving your
Contract Value and receiving the GLWB Payment from our General Account may be minimal”.

    Ms. Quarles

April 19, 2024

Page 3

In
the next sentence in the third paragraph, please add the word “an annual,” so the sentence states: “we assess
an annual fee” (emphasis added to show revisions).

 Response: The
                                         Company has made the requested revisions.

 7. As
                                         noted in Comment No. 4, several references on the cover page to six year terms were deleted
                                         in the amendment. Please advise what happened to the six-year allocation options. Are
                                         there any investors currently in a six-year term? If so, you may not delete, and must
                                         retain, the disclosure about six-year terms for all Contracts before May 1, 2024. Then,
                                         further explain how new Index options will have a one-year term.

 Response: Please
                                         see the response to Comment No. 4 above.

 8. In
                                         the sixth paragraph, please revise the first sentence so the sentence as follows: “We
                                         credit interest to the Risk Control Accounts at the end of each Contract year
                                         based in part on the performance of an external 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 (“Index Performance”).” (emphasis added
                                         to show revisions).

 Response: The
                                         Company has made the requested revisions.

 9. In
                                         the sixth paragraph, last sentence, please add “an annual,” so the sentence
                                         states as follows: “We charge an annual Contract Fee on amounts allocated
                                         to the Risk Control Accounts.” (emphasis added to show revisions).

 Response: The
                                         Company has made the requested revisions.

 10. In
                                         addition to the 10% additional tax, please reference tax penalties throughout the document.

 Response: The
                                         Company has made revisions to define and explain tax penalties. The Company respectfully
                                         submits that the 10% tax on withdrawals taken before Age 59½ is characterized
                                         by the Code and the IRS as an “additional tax” and not as a penalty, and
                                         therefore the Company uses that terminology.

 11. In
                                         the seventh paragraph, first bullet, last sentence, change the reference to “Floor”
                                         to “Growth Account” and delete the words “of up to the applicable Floor”
                                         so the sentence states as follows: “It is possible that you will not each 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 revisions.

 12. In
                                         the seventh paragraph, third bullet, add the following at the end of the last sentence:
                                         “and could terminate the GLWB and the Contract.”

 Response: The
                                         Company has made the requested revisions.

    Ms. Quarles

April 19, 2024

Page 4

  Glossary

 13. In
                                         the definition of “Allocation Options,” the Company added a sentence that
                                         states selling firms may limit available Allocation Options. The prospectus needs to
                                         include all material variations, including financial intermediary variations. Please
                                         disclose any such limits in the prospectus so that investors know what is available to
                                         them.

    Response:
    The Company has deleted the sentence and similar disclosures.

 14. In
                                         the definition of Pro Rata, delete “relative to” and retain the word “proportional”.

    Response:
    The Company has made the requested revision.

 Highlights

 15. Under
                                         How Your Contract Works – Overview, in the first paragraph, last sentence, delete
                                         “the Floor” and replace with “-10% for the Growth Account”.

    Response:
    The Company has made the requested revisions.

 16. Under
                                         How Your Contract Works – Overview, in the second paragraph, add the following
                                         after the third sentence: “The GLWB Payment is a withdrawal of your own Contract
                                         Value unless the Contract Value is reduced to zero. The probability of you outliving
                                         your Contract Value and receiving the GLWB Payment from our General Account may be minimal”.

    Response:
    The Company has made the requested revisions.

 17. Under
                                         How Your Contract Works – Overview, in the second paragraph, add the following
                                         to the last sentence: “which will be the greater of the GLWB Payment or the income
                                         payment under the income payout option elected.”

    Response:
    The Company has made the requested revisions.

 18. Under
                                         How Your Contract Works – Overview, in the third paragraph, add the following to
                                         the second sentence: “perhaps by more than the amount of the withdrawal.”

    Response:
    The Company has made the requested revisions.

 19. Under
                                         How Your Contract Works – Allocation Options, please include a chart showing the
                                         allocation options here and in the Allocation Options section, similar to the chart that
                                         the Company includes in its other product filings. Please be clear about what is available
                                         for Contracts before May 1, 2024 and after May 1, 2024, even if the options are similar.

    Response:
    The Company has made the requested revisions.

 20. Under
                                         How Your Contract Works – Allocation Options - Risk Control Accounts, in the first
                                         paragraph, change the word “Index” to “Indices” in the next to
                                         last sentence.

    Response:
    The Company has made the requested revisions.

    Ms. Quarles

April 19, 2024

Page 5

 21. Under
                                         How Your Contract Works – Allocation Options – Risk Control Accounts, in
                                         the second paragraph, revise the first sentence to state as follows: “The Floor
                                         is the maximum amount of negative interest we will credit you, prior to the deduction
                                         of the Contract Fee and GLWB Rider Fee.” (emphasis added to show revisions).

    Response:
    The Company has made the requested revisions.

 22. Under
                                         How Your Contract Works – Allocation Options – Risk Control Accounts, in
                                         the second paragraph, revise the last sentence to state as follows: “However, you
                                         could lose more than 10% of your investment in a Risk Control Account each Contract
                                         Year due to the application of the Contract Fee, the GLWB Rider Fee, Surrender Charge,
                                         a negative Market Value Adjustment, federal income taxes, and a 10% additional tax.”
                                         (emphasis added to show revisions).

    Response:
    The Company has made the requested revisions.

 23. Under
                                         How Your Contract Works – Allocation Options – Risk Control Accounts, in
                                         the third paragraph, revise the first sentence to state as follows: “The Cap is
                                         the maximum amount of positive interest we will credit you, prior to the deduction
                                         of the Contract Fee and GLWB Rider Fee.” (emphasis added to show revisions).

    Response:
    The Company has made the requested revisions.

 24. Under
                                         How Your Contract Works – Allocation Options – Risk Control Accounts, in