SecProbe.io

April 22, 2020
Todd Larson
Senior Executive Vice President & Chief Financial Officer
REINSURANCE GROUP OF AMERICA INC
16600 Swingley Ridge Road
Chesterfield, Missouri 63017
Re:REINSURANCE GROUP OF AMERICA INC
Form 10-K for the Fiscal Year Ended December 31, 2019
Filed February 27, 2020
File No. 001-11848
Dear Mr. Larson:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2019
Notes to consolidated financial statements
Note 2: Significant Accounting Policies
Future Policy Benefits, page 98
1.Although you disclose your policy for short-duration premium deficiency assessments in
the third paragraph of this policy note, you do not appear to disclose your policies for:
•Short-duration premium recognition;
•Short-duration claims reserving; and/or
•The amortization of deferred policy acquisition costs for short-duration contracts.
Please provide us proposed revised disclosure for these policy statements to be included in
future periodic reports.  Otherwise tell us where you disclose these policies or why their
disclosure is not warranted.
Note 16: Policy Claims and Benefits
Rollforward of Claims and Claim Adjustment Expenses, page 146

 FirstName LastNameTodd Larson
 Comapany NameREINSURANCE GROUP OF AMERICA INC
 April 22, 2020 Page 2
 FirstName LastName
Todd Larson
REINSURANCE GROUP OF AMERICA INC
April 22, 2020
Page 2
2.You disclose unfavorable prior year development on incurred claims of $154 million in
2019.  Given that this amount is significant to your pre-tax income of $1,132 million in
2019, please tell us how your disclosure provides useful information to financial statement
users to facilitate their analysis of the amount, timing, and uncertainty of cash flows
arising from insurance contracts and the development of the liability for unpaid claims
consistent with the objective outlined in paragraph BC 2 of ASU 2015-09.  In your
response tell us:
•How your disclosure complies with the guidance in ASC 944-40-50-3.  In this regard,
your disclosure appears to merely identify prior year development but fails to explain
the underlying reasons for this development.
•The components of your $154 million unfavorable development over and above the
apparent $28 million in aggregate unfavorable development ($5 million favorable in
your U.S. and Latin America short-duration contracts offset by $33
million unfavorable in your Asia Pacific short-duration contracts) depicted in
your claims development tables on pages 144 and 145.  At a minimum, provide the
following components for the apparent $126 million in incremental unfavorable
development:oThe amount of prior year development for accident years prior to 2012 for each
of the claims development tables referred to above;
oThe short-duration lines of business not included in the claims development
tables and the prior year development for those lines in 2019 for each line; and
oThe amount of prior year development related to your long-duration claims;
•Why you do not include the short-duration lines of business identified in the
preceding bullet in your tables;
•Whether the prior year development on your long-duration claims is offset by an
opposite impact on your liability for future policy benefits; and
•Your consideration for disclosing the information in the preceding bullets.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Dave Irving at 202-551-3321 or Mark Brunhofer at 202-551-3638 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance