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2012-12-21 SEC Letter of Comments Initial Response

January 2, 2013

Jim B. Rosenberg

Senior Assistant Chief Accountant

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Re: American Equity Investment Life Holding Company

Form 10-K for the Fiscal Year Ended December 31, 2011

Filed March 1, 2012

Form 8-K dated November 5, 2012

Filed November 6, 2012

File No. 001-31911

Dear Mr. Rosenberg:

I received your comment letter dated December 21, 2012 requesting a response within 10 business days. Due to the holiday season and our staff's time away we have determined that we will need some additional time beyond 10 business days to appropriately respond to all of your comments. We will submit our response on or prior to January 15, 2013, which would be within 15 business days.

Sincerely,

/s/ Ted M. Johnson

Ted M. Johnson

Chief Financial Officer and Treasurer