SecProbe.io

August 8 , 2013

Via E-mail
Mr. 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 the Fiscal Year Ended December 31 , 2012
Filed March 1, 2013
File No . 001-11848

Dear M r. Lay:

We have limited our review  to only your financial statements and related disclosures and
do not intend to expand our review to other portions of your documents.  In our comments , we
ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 business days by providing the requested
information  or by advising us when you will provide the requested response.   If you do not
believe a comment appl ies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the form type label CORRESP that key s your
responses to our comments.

After reviewing the information provided, we may have additional comments and/or
request that you amend your filing.

Notes to the Consolidat ed Financial Statements

Note 4. Investments
Mortgage Loans on Real Estate, page 101

1. Please tell us how evaluating $2,272,211,000  of your mortgage loans collectively for credit
losses complies with ASC 310 -10-35.  In this regard, provide us your analysis b y “property
type” of loan that supports not evaluating these loans individually.

Note 14.  Collateral Finance  Facility, page 137

2. Regarding Timberlake Re, a wholly -owned subsidiary of Timberlake Financial and a South
Carolina captive insurance company in which specified term life i nsurance policies re insured
by RGA Reinsurance a re retroceded to it, please tell  us:

Mr. Jack B. Lay
Reinsurance Group of America, Inc.
August 8, 2013
Page 2

  The business purpose of transactions with Timberlake Re.  Explain whether, and if so,
to what extent, Timberlake Re reinsures from third parties to whom you ceded
policies.
 The amount of Tim berlake Re’s obligations and the nature and amount of assets,
guarantees, letters of credit or promises that secure its obligations.  Tell us the nature
and amount of  RGA’s assets, guarantees, letters of credit or promises  securing the
Timberlake Re’s oblig ations.
 The effects in your GAAP consolidated financial statements of transacting with
Timberlake Re directly and, if applicable, indirectly through third parties.
 Your consideration of disclosing the risks of employing your captive strategy.
 Any uncer tainties associated with the continued use of this strategy and the expected
effects on your financial position and results of operations if you discontinue this
strategy.

We urge all persons who are responsible for the 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 require.   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 t he disclosures they have made.

 In responding to our comment s, please provide  a written 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 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  federal securities laws of the United States.

You may contact Christine Allen, Staff Accountant , at (202) 551 -3652  if you have
questions regarding the comment s.  In this regard, do not hesitate to contact me at (202) 551 -
3679.

Sincerely,

/s/ Jim B. Rosenberg

Jim B. Rose nberg
Senior Assistant Chief Accountant