SecProbe.io

May 27, 2011
 C. Robert Henrikson Chairman of the Board, President and Chief Executive Officer MetLife, Inc. 200 Park Avenue New York, N.Y. 10166-0188
Re: MetLife, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2010 Filed February 25, 2011
  File No. 001-15787

Dear Mr. Henrikson:

We have limited our review of your filing to  those issues we have addressed in our
comments.  In our comments, we ask you to pr ovide us with information so we may better
understand your disclosure.

Please respond to this letter within te n business days by providing the requested
information or by advising us when you will provide the requested response.  Where a comment
requests you to revise disclosu re, the information you provide s hould 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 be lieve a comment applies to your facts and
circumstances, please tell us why in your res ponse.  Please furnish us a letter on EDGAR under
the form type label CORRESP that ke ys your responses to our comments.

After reviewing the information you provide in response to these comments, we may
have additional comments and/or request that you amend your filing.

Item 7.  Management’s Discussion and Analysis

Industry Trends
Mortgage and Foreclosure- Related Exposures, page 77

1. You disclose on page 77 that other than repurchase obligations which are subject to
indemnification by sellers of acquired assets …(your) exposure to re purchase obligations
and losses related to origination deficiencies is limited to the approximately $52 billion of
loans originated by MetLife Ba nk (all of which have been originated since August 2008)
and to servicing deficiencies after the date of acquisition, and management is satisfied
that adequate provision has been made in  the Company’s consolidated financial
statements for all probable and reasonably es timable repurchase oblig ations and losses.
Please disclose the following within your Notes:

C. Robert Henrikson
Metlife, Inc. May 27, 2011 Page 2

 The amount of your accrual for loan repur chases as of December 31, 2010, and the
impact of loan repurchases on your results of operations for each period presented;
 The amount of loans you repurchased in each period presented;
 The amount of loans for which the acquirers of your originated loans are seeking to
be repurchased by you; and
 Your methodology for estimating the accrual for loan repurchases.

Composition of Investment Portfolio and Investment Portfolio Results

Fixed Maturity and Equity S ecurities, Available for Sale
Fixed Maturity Securities Credit Quality — Ratings, page 132

2. On page 133 you present a table of fixed matu rity securities, based on estimated fair
value, by sector classification and by  NRSRO designation and the equivalent
designations of the NAIC.  Please tell us whether you perform an analysis, including
considering current market credit spreads, for your investments, to determine either that
the ratings assigned by the third party cred it rating agencies are reasonable or to
otherwise determine the credit quality of your investments.   If so, please summarize for
us the procedures you perform.  Also, tell us the investments for which you performed
these procedures and, for those where these procedures resulted in you concluding that
the rating assigned by the third party credit rating agency at December 31, 2010 was significantly different, provide th e fair value and amortized cost  of those investments, as
well as how and why your conclusion differed.
 Investments

Composition of Investment Portfolio and Investment Portfolio Results
Mortgage Loans
Mortgage Loan Credit Quality — Restructured , Potentially Delinquent, Delinquent or Under
Foreclosure, page 143

3. For your loan modification activity, please revise your disclosure to address the
following:
 The types and amount of loans for which you modified the original terms of the
contract;
 Quantify the default and/or success rate s of these loan modifications; and
 Clarify whether these modified loan s are in your performing portfolio.

C. Robert Henrikson
Metlife, Inc. May 27, 2011 Page 3

Item 8.  Financial Statements and Supplementary Data

Notes to the Consolidated Financial Statements
 1. Business, Basis of Presentation and Su mmary of Significant Accounting Policies

Summary of Significant Accounting Polic ies and Critical Accounting Estimates
Investments
Mortgage Loans — Mortgage Loans Held-For-Investment
Commercial, Agricultural  and Residential Mortgage Loans, page F-14

4. Regarding your non-specific valuation allo wance established for pools of loans with
similar risk characteristics, you disclose on pa ge F-15 that you typica lly use ten years, or
more, of historical experience,  in these evaluations.  Pleas e revise your disclosure to
discuss the extent to which you adjust your calcul ations to give greate r weight to the most
recent years.  Given that the recent credit en vironment represented by the later years in
your 10-year look-back period wa s significantly different than  the earlier years in your
look-back period, please provi de a comprehensive discus sion of your views and
judgments in making your ultimate determinatio n whether to adjust or apply weighting to
the look-back period.
 Commercial and Agricultural Mortgage Loans, page F-15

5. You disclose for commercial loans, your prim ary credit quality indicator is the debt
service coverage ratio, which compares a property’s net operating income to amounts
needed to service the principal and interest due under the loan.  You also disclose the
values utilized in calcula ting these ratios are developed in connection with the ongoing
review of the commercial loan portfolio  and are routinely updated.  Based on your
disclosure on page F-77, it a ppears loan-to-value ratios are also a credit quality indicator
for commercial mortgage loans.  Please revise  your disclosure to specifically state the
date or range of dates on which the debt serv ice coverage ratios, loan-to-value ratios, and
values utilized in calculating these ratios were updated.  In this regar d, specifically clarify
what you mean by ongoing and routinel y.  Refer to ASC 310-10-50-29(c).
 Real Estate Joint Ventures and Other Li mited Partnership Interests, page F-17

6. You disclose that you use the cost method of  accounting for investments in real estate
joint ventures and other limited partnership interests in which you have a minor equity
investment and virtually no influence over the joint vent ures or the partnership’s
operations.  Please tell us how you consid ered the guidance in ASC 944-325-30-1 and
944-325-35-1 in not accounting for these investments at fair value.

C. Robert Henrikson
Metlife, Inc. May 27, 2011 Page 4

2.  Acquisitions and Dispositions

2010 Acquisition of ALICO
Recording of Assets Acquired and Liabilities Assumed
Identified Intangibles, page F-44

7. Regarding the $4.4 billion negative VOBA r ecorded at the acquisition date, please
address the following:
 Tell us the nature of the business and wh en it was written regarding the “certain
acquired blocks of business” for which negative VOBA was recorded and why the
fair value of liabilities associated with  this business exceeded the “initial policy
reserves assumed.”
 Tell us your accounting policy fo r recording the “i nitial policy reserv es assumed” for
these blocks of business and how record ing negative VOBA complied with ASC 944-
805-30-1.
 Disclose in what circumstances you woul d amortize the negative VOBA over the
approximate consumption of losses included in the liability.  Pr ovide us with your
accounting analysis related to this method, including references to the accounting
literature upon which you relied.
 Disclose the estimated amortization pe riod for your negative VOBA and the
estimated amortization for each of the next five years.
 16.  Contingencies, Commitments and Guarantees

Contingencies
Litigation, page F-165

8. You disclose estimates of possible losses or ra nges of loss for partic ular matters cannot in
the ordinary course be made with a reasonable degree of certainty.  You also disclose it is
possible that some of the matters could re quire the Company to pay damages or make
other expenditures or establish accruals in amounts that could not be estimated at
December 31, 2010.  It appears your threshold fo r disclosure is whether you can estimate
possible losses or ranges of loss with a reasonable degree of  certainty.  We do not believe
this criterion is consistent with the guidance in ASC 450.  Please revise your disclosure to
either provide an estimate of the possible loss or range of loss, or provide explicit
disclosure for each of the litigation matters  that you are unable to estimate the possible
loss or range of loss.  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.

C. Robert Henrikson
Metlife, Inc. May 27, 2011 Page 5

In responding to our comments, please provi de 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 Staci Shannon, Staff Account ant, at (202) 551- 3374 or Mary Mast,
Review Accountant, at (202) 551-3613 if you have questions regarding the comments.  In this
regard, do not hesitate to contact me at (202) 551-3679.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant