SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 4720

         June 22, 2009

Jack B. Lay
Senior Executive Vice President and
Chief Financial Officer
Reinsurance Group of America, Inc.
1370 Timberlake Manor Parkway
Chesterfield, MO 63017

Re:   Reinsurance Group of America, Inc.
 Form 10-K for Fiscal Year Ended December 31, 2008
 Filed March 2, 2009
File Number:  001-11848

Dear Mr. Lay:

We have reviewed your filing and have the following comments. We have limited
our review to your financial statements a nd related disclosures and do not intend to
expand our review to other portions of your document.  In our comments, we ask you to provide us with information to better unde rstand your disclosure.  Where a comment
requests you to revise disclosure, the info rmation you provide should show us what the
revised disclosure will look like and identify the annual or quarterly filing, as applicable,
in which you intend to first include it.  If you do not believe that revised disclosure is
necessary, explain the reason in your response.  After reviewing the information
provided, we may raise additional comments and/or request that you amend your filing.

 Please understand that the purpose of our re view process is to assist you in your
compliance with the applicable disclosure requirements and to enhance the overall
disclosure in your filing.  We look forward to  working with you in these respects.  We
welcome any questions you may have about our  comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations

Liquidity
Reinsurance Operations, page 57
 1. Please revise your disclosure to quantify th e treaties with recapture options and the
amount of in force policies for which th e recapture option ha s been triggered.
Disclose the terms that trigged the recaptu re options and the accounting implication in
the event that the triggered options were exercised.  Also disclose the amount of

Jack B. Lay
Reinsurance Group of America, Inc.
June 22, 2009 Page 2
treaties recaptured during the periods presented and the im pact of the recapture on
your financial statements.

Contractual Obligations, page 59

2. Please revise your disclosure of future polic y benefits to explain why the total amount
of payments ($198.2) for this liability at  December 31, 2008 varies significantly from
year to year.  Previously you disclosed that  total future policy benefit payments were
($6,826.2) and $22,642.5 at December 31, 2007, and 2006, respectively. Provide a reconciliation between the total amount here and the corres ponding balance sheet
amount and state, if true, that the estima ted cash flows presented are not discounted.
Also, please explain to us how the expected premiums exceed expected policy benefit payments and allowances resulting in negative obligations.
 Recognition of Revenues and Related Expenses, page 94

 3. Please revise your disclosure to show th e minimum guaranteed rate for each major
interest-sensitive and investment–type product and the current weighted average interest-crediting rate. Quan tify and provide additional disclosure regarding your
increased exposure to losses due to the di fference between average crediting rates and
the average minimum guaranteed rates for th e current period. Pleas e also disclose the
combination of rate actions and portfolio management that you expect to undertake to
manage the effects of credit spreads on near-term income from operations.
 Consolidated Financial Statements

Notes to Consolidated Financial Statements
Note 9.  Income Tax, page 115
 4. Please revise to disclose the amount of the unrecognized deferred tax liability for
temporary differences related to investment s in foreign subsidiaries or state that
determination of the amount is not practi cable.  Refer to paragraph 44 of SFAS 109.

* * * *

 Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Pl ease furnish a cover le tter with your response
that keys your response to our comments.  De tailed cover letters gr eatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

 We urge all persons who are responsible  for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating to a company’s disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.

Jack B. Lay
Reinsurance Group of America, Inc.
June 22, 2009 Page 3

 In connection with responding to our co mments, please provide, in your letter, a
statement from the company acknowledging that:

• the company is responsible for the adequacy and accuracy of the disclosure in
the filing;
• staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking a ny action with respect to the filing;
and
• the company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any pers on under the federal s ecurities laws of
the United States.

 In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.

You may contact Dana Ha rtz, Staff Accountant, at (202) 551-3648 or Don
Abbott, Review Accountant, at (202) 551-3608 if you have any questions regarding the
comment.  In this regard, do not hesi tate to contact me, at (202) 551-3679.

        S i n c e r e l y ,

        J i m  B .  R o s e n b e r g
Senior Assistant Chief
Accountant