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SEC Response #3 (333-290025)

 Eversheds Sutherland (US) LLP

1114 Avenue of the Americas, 40th

 Floor
New York, NY
10036-7703

 D: +1 212.389.5080
F: +1 212.389.5099

 dodiekent@

eversheds-sutherland.com

 April 17, 2026

 Via
Correspondence

 U.S. Securities and Exchange Commission

100 F Street, NE

 Washington, DC 20549

Attn: Anu Dubey

 Division of Investment Management

Re:
 Brighthouse Life Insurance Company

 
 Brighthouse Retirement Account Annuity

 
 Post-Effective Amendment No. 1 to the Registration Statement on Form
N-4

 
 File No. 333-290025

Dear Ms. Dubey,

 On behalf of Brighthouse Life Insurance
Company (the “Company”), we are responding to the comment you conveyed on March 31, 2026, with regard to the Company’s above-referenced
filing (the “Amendment”). This letter has been filed as Correspondence, and the Company’s corresponding revisions will be included in the Amendment before it is effective.

The staff’s comment is repeated below, followed by the Company’s response.

Comment:

 Please confirm to us that there are no material
state variations to the guaranteed minimum interest rate (“GMIR”) and any disclosures suggesting otherwise have been removed.

Response:

 The Company confirms that there are currently
no state variations, material or otherwise, with regard to the GMIR absolute floor employed by the Company, which is 1%. Accordingly, the Company has removed any disclosures that suggest
otherwise.

 Nevertheless, the Company feels compelled to note that it continues to believe that even if the
Company did, in fact, implement a higher GMIR floor in a given state, any such higher floor would not constitute a material state variation.

1     

54397636.1

 Eversheds Sutherland (US) LLP

1114 Avenue of the Americas, 40th

 Floor
New York, NY
10036-7703

 D: +1 212.389.5080
F: +1 212.389.5099

 dodiekent@

eversheds-sutherland.com

 As background, the Company notes that all states follow a version of the NAIC Standard

Nonforfeiture Law for Individual Deferred Annuities (“SNFL”). The SNFL, which includes the

mandated GMIR, has changed several times over the years, and such changes are implemented

(or not) by states on differing timelines. In turn, companies themselves implement those changes

on differing timelines. Accordingly, GMIRs not only vary from state to state, but within any

given state over time, as well as across contracts and/or contract iterations covered by the same

prospectus and/or registration statement.

 As further background,
starting in 2003, following a prolonged low-interest rate environment,

 the NAIC abandoned its historical
prescribed single minimum guaranteed rate approach (which

 itself had varied from time to time over the years) and adopted the current
indexed-linked

 approach, with an absolute floor of 1%. Later, faced with another prolonged ultra-low-interest

 rate environment, in 2020, the NAIC lowered the GMIR absolute floor to 0.15%. This
decrease

 was adopted by many but not all states. Today, given this index-linked approach, when we

disclose a contract’s lowest possible crediting rate, we are disclosing the absolute floor as

opposed to the actual GMIR applicable to any given contract (which is unknown, based on the

index calculation, until the contract issue date).

 Notably, the
current version of SNFL allows for: (i) a permanent GMIR for the life of a contract

 based on the indexed formula on the date of contract issue,
or (ii) a GMIR that resets periodically

 over the life of the contract based on the indexed formula, both subject to the
applicable absolute

 floor. Accordingly, some issuers set a GMIR that is permanently fixed on the contract date,

while other issuers have GMIRs that vary from year to year.

 The
industry practice of disclosing a single GMIR, i.e., the lowest possible rate that could be

 applied to any contract covered by the prospectus, is
attributable to this complex and non-static

 framework. Nonetheless, over this long history, it has succeeded in
providing the contract owner

 with the material information s/he needs: the lowest possible fixed account rate that could be

credited to fixed account assets – the absolute floor a Company will/can use in connection

with the SNFL in any state.

Respectfully, this long-term historical practice of disclosing the lowest possible GMIR was not

arrived at thoughtlessly. Such disclosure provides material information to a prospective

purchaser without the undue complications of references to state-specific GMIR absolute floors

that may be nominally higher and overwhelmingly not employed. Moreover, disclosing GMIR

state variations applicable to unregistered fixed investment options is not, and never has been,

industry practice.

2     

54397636.1

 Eversheds Sutherland (US) LLP

1114 Avenue of the Americas, 40th

 Floor
New York, NY
10036-7703

 D: +1 212.389.5080
F: +1 212.389.5099

 dodiekent@

eversheds-sutherland.com

 We end as we began – the fact that there may be a nominally higher GMIR floor in a given state
is not something an investor would reasonably view as important in making the decision to allocate their account value to an unregistered fixed account and is therefore not
material.

 Nevertheless, currently, the Company utilizes a common 1% GMIR absolute floor in every state
and it has revised its disclosure on this point for clarity.

*  *  *        

If you have any additional questions or concerns, please contact the undersigned by telephone at
(212) 389-5080, or by email at dodiekent@eversheds-sutherland.com.

 Very truly
yours,

 /s/ Dodie C. Kent

 Dodie C. Kent

Partner, Eversheds Sutherland (US) LLP

cc:   

 Michele H. Abate, Head of Securities Products & Funds Law, Brighthouse Financial

Alyson Saad, Managing Corporate Counsel, Brighthouse Financial

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54397636.1