SecProbe.io

Via Facsimile and U.S. Mail
Mail Stop 4720           April 30, 2010   Mr. William J. Wheeler Executive Vice President and Chief Financial Officer  MetLife, Inc.    200 Park Avenue New York, New York 10166
Re:   MetLife, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2009
 Filed February 26, 2010
 File Number:  001-15787

Dear Mr. Wheeler:

We have reviewed your filing and have the following comments. We have limited
our review to your financial statements a nd related disclosures and do not intend to
expand our review to other portions of your document. In our comments, we ask you to
provide us with information to better unde rstand your disclosure.  Where a comment
requests you to revise disclosure, the info rmation you provide should show us what the
revised disclosure will look like and identify the annual or quarterly filing, as applicable,
in which you intend to first include it.  If you do not believe that revised disclosure is
necessary, explain the reason in your response.  After reviewing the information
provided, we may raise additional 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  comments or on any other aspect of our
review.  Feel free to call us at the telephone numbers listed at the end of this letter.

Item 7- Management Analysis of Fina ncial Position and Results of Operations

Summary of Critical Accounting Estimates
Embedded Derivatives, page 73
 1. Please revise your disclosure to include qua ntified and narrative disclosure of the
impact that reasonably likely changes in the company’s own credit risk used to
estimate fair value would have  on the financial statements.

Mr. William J. Wheeler
MetLife, Inc. April 30, 2010 Page 2  Consolidated Results of Operations

Year Ended December 31, 2009 compared with the Year Ended December 31, 2008,
page 80
 2. Please revise your disclosure to re concile the amount disclosed for the
unfavorable variance in net investment ga ins (losses) of $5.2 billion to the amount
disclosed on the income statement. Pleas e disclose the amounts attributable to
each factor included to explain the nega tive change in freestanding derivatives on
page 82. Finally, please disclose the am ount of the losses attributable to a
narrowing of the company’s own credit spread.
 3. Please include an explanation for the ch ange in the provision for income tax
expense (benefit) in results of operations.
 4. In your discussion of other expenses you re ference several factor s that contributed
to the increase in expense.  This discu ssion did not quantify the impact that each
of these significant factors had individuall y.  Please revise your disclosure to
quantify the changes that resulted from each  of the significant factors referenced.
This also applies to other disclosure in your document where multiple factors are
referenced, but not quantified.

Notes to the Consolidated Financial Statements

Note 3. Investments
Mortgage Loans, page F-65
 5. Please disclose, preferably in a table, lo ans in your commercial loan portfolio
grouped by current loan-to-value ratio, as appropriate, to provide informative
disclosure about different levels of  loan-to-value ratio along with the
corresponding fair value. For example, gr oupings could include loans classified as
low, medium or high loan-to-value ratio with a note explaining the definition of
low, medium and high.

* * * *

 Please provide us the information request ed within 10 busine ss days or tell us
when you will provide us with a response.  Pl ease furnish a cover le tter with your response
that keys your response to our comments.  De tailed cover letters gr eatly facilitate our
review.  Please furnish your letter on EDGAR under the 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.

Mr. William J. Wheeler
MetLife, Inc. April 30, 2010 Page 3

 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 a ny 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 pers on under the federal s ecurities laws of
the United States.

 In addition, please be advi sed that the Division of En forcement 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 Vanessa R obertson, Staff Accountant, at (202) 551-3649 or
Mary Mast, Senior Staff A ccountant, at (202) 551-3613 if you have any questions
regarding the comments.  In th is regard, do not hesitate to  contact me, at (202) 551-3679.
          S i n c e r e l y ,

        J i m  B .  R o s e n b e r g
Senior Assistant Chief Accountant