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Via Facsimile and U.S. Mail Mail Stop 4720                                                                                                   May 20, 2010   A. Greig Woodring President and Chief Executive Officer Reinsurance Group of America, Incorporated  1370 Timberlake Manor Parkway Chesterfield, Missouri 63017
Re: Reinsurance Group of America, Incorporated
 Form 10-K for the Year Ended December 31, 2009  Filed February 26, 2010  File No. 001-11848  DEF14 A   Filed April 8, 2010  File No. 001-11848

Dear Mr. Woodring:

We have reviewed your filing and have the following comments.

In our comments, we ask you to provide us with information to better understand
your disclosure. Where it requests you to revi se disclosure, the information you provide
should show us what the revised disclosure  will look like and identify the annual or
quarterly filing, as applicable, in which you inte nd to first include it. If you do not believe
that revised disclosure is n ecessary, explain the reason in your  response.  After reviewing
the information provided, we may raise a dditional 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 comment or on any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

A. Greig Woodring
Reinsurance Group of America, Incorporated
May 20, 2010 Page 2  DEF14A

Item 1. Election of Directors, page 2
Qualifications of Directors, page 5

1. We note that you have included a gene ral discussion of the qualifications,
expertise and attributes of  your directors.  Please note that Item 401 (e) of
Regulation S-K requires disc losure of the specific “e xperience, qualifications,
attributes or skills of direct ors and nominees on an individu al basis.  Please revise
your disclosure to address the requireme nts of Item 401 (e) on an individual
director basis.  Your disclosure should address the specific experience, qualifications, attributes and skills of each director or nominee.  A mere listing of each director or nominee’s prior work experi ence is not sufficient.  Please revise
accordingly.
 Executive Compensation, page 21

Summary Compensation Table, page 21

2. We note Footnote 3 to the Summary Compensation Tabl e in which you indicate
that the option awards have been presente d at the grant date fair value of stock
options granted in accordance with SFAS 123R.  Please advise us of any
difference in the values presented had you included the aggregat e grant date fair
value computed in accordance with FASB  ASC Topic 718, as re quired under Item
402 (c) (v) of Regulation S-K.

*    *    *    *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a cover letter  that keys your response to
our comment and provide any requested information.  Detailed letters greatly facilitate our review.  Please file y our letter on EDGAR under th e 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.
  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

A. Greig Woodring
Reinsurance Group of America, Incorporated May 20, 2010 Page 3
 foreclose the Commission from taking any 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 person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement 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 comment on your filing.
Please contact Nandini Acharya at (202) 551-3495 or me  at (202) 551-3715 with
any questions.

    Sincerely,

Jeffrey P. Riedler Assistant Director