SecProbe.io

April 30, 2012
 Via E-mail

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 Fiscal Year Ended December 31, 2011 Filed February 29, 2012 File No. 001-11848

Dear Mr. Woodring:
 We have reviewed your filing and have the following comments.
 Please respond to this letter within 10  business days by amending your filing or by
advising us when you will provide the requested  response.  If you do not believe a comment
applies to your facts and circumstances or do not believe an amendment is appropriate, please
tell us why in your response.  Please furnish us a letter on EDGAR under the form type label
CORRESP that keys your responses to our comments.
 After reviewing any amendment to your filing and the information you provide in
response to these comments, we may have additional comments.

Item 8.  Financial Statements and Supplementary Data

Notes to Consolidated Financial Statements
 Note 2  Summary of Significant Accounting Policies

Recognition of Revenues and Related Expenses, page 87

1. You disclose ranges of guaranteed interest ra tes for your interest se nsitive contracts.
Please revise your MD&A to include disclosure that quantifies the di stribution of each of
your interest sensitive account values within each range.
 Note 11. Financial Condition and Net Income on a Statutory Basis - Sign ificant Sudsidiaries-

(Unaudited), page 124

2. With respect to your statutory disclosure s please amend your filing to address the
following:

A. Greig Woodring
President and Chief Executive Officer Reinsurance Group of America, Incorporated  April 30, 2012 Page 2

  The disclosure in this Note  is required by ASC 944-505-50 a nd is thus required to be
audited.  Please revise your filing to in clude the information on an audited basis.
 Disclose the statutory capital and surplus n ecessary to satisfy regulatory requirements
in each jurisdiction pursuant to ASC 944-505-50-1.
 You state that “The total cap ital and surplus positions of  the Company’s primary life
reinsurance legal entities ex ceed the capital requirements of  the applicable regulatory
bodies.”  Please clarify what is meant by “the Company’s primary life reinsurance
legal entities”.  Explain why you have not provided an analysis for all your
reinsurance legal entities.
 Please tell us why the disclosures in AS C 944-505-50-2 through 50- 6 are not required
or revise to provide th e required disclosures.
 We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules requir e.  Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.
 In responding to our comments, please provi de a written statement from the company
acknowledging that:
 the company is responsible for the adequacy an d accuracy of the disclo sure in the filing;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and
 the company may not assert staff comments as  a defense in any proceeding initiated by
the Commission or any person under the federa l securities laws of  the United States.

Please contact James Peklenk, Staff Accountant,  at (202) 551-3661 or Mary Mast, Senior
Accountant, at (202) 551-3613 if you have any questions regarding the comments. In this regard,
do not hesitate to contact me at (202) 551-3679.

Sincerely,  /s/ Jim B. Rosenberg  Jim B. Rosenberg Senior Assistant Chief Accountant