SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 0610     June 10, 2009

 Richard S. Collins, Esquire Senior Chief Counsel MetLife, Inc. 200 Park Avenue New York, New York 10166-0188  Re: MetLife, Inc.  Form 10-K for the fiscal year ended December 31, 2008
 Definitive Proxy statement filed March 31, 2009  File No. 001-15787  Dear Mr. Collins:
We have reviewed your response dated April 30, 2009 and have the following
comments.  In our comments, we ask you to provide us with information to better understand your disclosure.  Where a comment asks you to revise disclosure, the information you provide should show us what the revised disclosure will look like prior to amending your Form 10-K.  If you do not belie ve that revised disclosure is necessary,
please explain the reason in your response.  After reviewi ng the information provided, we
may raise additional comments and/or request that you further 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 any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Compensation Discussion and Analysis

1. We note your response to comment 1.  Disc losure of your Corporate and the NEO
individual goals and the extent to whic h these goals were achieved should be
presented in the Compensation Discussion and Analysis in either your Form 10-K
or your proxy statement.  Additionally, th e discussion should clarify the extent to
which the goals were achieved and how th is information was used to determine
compensation.  Therefore, you should discuss how the maximum amount available for AVIP awards is determined and that each individual’s award is discretionary and determined by the Compen sation Committee.  Please provide us

with draft disclosure to s how us how you intend to present this information for the
year ended December 31, 2009.

* * * * *

 Please provide us the information request ed within 10 business days of the date
of this letter or tell us when you will provide a respons e prior to the expiration of the 10-
day period.  Please furnish a letter with your responses that keys your responses to our
comments.  Detailed cover letters greatly f acilitate our review.  You should furnish the
letter on EDGAR under the form type label CORRESP.
   We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that th e filing includes all info rmation required under
 the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed decision.  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 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 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 comments on your filing.

 You may contact John L. Krug, Senior  Counsel, at (202) 551-3862, Suzanne
Hayes, Legal Branch Chief, at (202) 551- 3675, or me at (202) 551-3715 if you have any
questions.
Sincerely,   Jeffrey Riedler Assistant Director