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Independent Ratings
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| A.M. Best
(as of July 2007)
|
A+
(Superior)
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|
[This
rating is assigned to companies that have, on balance, superior balance sheet
strength, operating performance and business profile when compared to the
standards established by A.M. Best Company. These companies have a very strong
ability to meet their ongoing obligations to policyholders.]

"...reflects the
company's leading market position in the small-to-medium size not-for-profit
annuity and pension sector, the benefits derived from its non-commissioned
field force, and strong absolute and risk-adjusted
capitalization... The company continues to expand its presence in the
for-profit sector, serving small to medium-sized companies."
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| Standard & Poor's
(as of August 2007)
|
AA-
(Very Strong)
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|
[This
rating is assigned to life insurance companies that have very strong financial
security characteristics, differing only slightly from those rated higher.]

"...reflects Mutual of
America's strong niche and competitive position as a pension provider to
nonprofit organizations and small-to-midsize for-profit companies, consistent
growth in its target market and extremely strong capitalization."
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| Fitch
(as of January 2008)
|
AA-
(Very Strong)
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|
[This
rating indicates a very strong capacity to meet policyholder and contract
obligations on a timely basis. This capacity is not significantly vulnerable to
foreseeable events.]

"...reflects Mutual of
America's extremely strong capitalization, the Company's below-average exposure
to risky assets and Mutual of America's established niche in the small to
medium-size not-for-profit group pension market."
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| While the
ratings do not apply to the safety or investment performance of the Separate
Account Investment Funds, they do reflect upon Mutual of America's ability to
fulfill its General Account and annuity purchase rate guarantees. |