SecProbe.io

Mail Stop 6010

 December 6, 2007

A. Greig Woodring
Chief Executive Officer Reinsurance Group of America, Incorporated 1370 Timberlake Manor Parkway Chesterfield, MO  63017
Re: Reinsurance Group of America, Incorporated  Definitive Proxy Statement
Filed April 11, 2007
 File No. 001-11848
 Dear Mr. Woodring:
We have reviewed your response letter  dated October 25, 2007 and have the
following comments.  Please respond to our comments by December 20, 2007 or tell us
by that time when you will provide us with a response.  If the comments request revised disclosure in future filings, please confir m in writing that you will comply with the
comments in your future filings and also ex plain to us how you intend to comply.  We
welcome any questions you may have about our comments or any other aspect of our review.  1. We note your response to prior comment 2 and 5.  With respect to your employee
solicitation concerns, it is unc lear why the disclosure of the target information on
a historical basis would be any more useful  to your competitors or cause any more
competitive harm than the disclosure of  the actual compensation paid to the
named executive officers that is already contained in your proxy statement.  It is also unclear why such information would not be material to your shareholders'
understanding of your prior year's compen sation decisions with respect to the
named executive officers.  As such, we continue to believe that you should disclose the specific quantitative and qua litative aspects of the performance
objectives used to determine incentive payments and grants for the prior fiscal year in your future filings.
 2. As requested in our prior letter, please provide, in writing, a statement from the
company acknowledging that:

• the company is responsible for the adequacy and accuracy of the
disclosure in the filing;

Reinsurance Group of America, Incorporated December 6, 2007 Page 2

• staff comments or changes to disclo sure in response to comments do not
foreclose the Commission from taki ng any action with respect to the
filing; and

• the company may not assert staff comments as a defense in any
proceeding initiated by the Commissi on or any person under the federal
securities laws of the United States.

If you have any questions, pleas e contact me at (202) 551-3635.

        S i n c e r e l y ,             T i m  B u c h m i l l e r          S e n i o r  A t t o r n e y