SecProbe.io

June 7, 201 2

Via E -mail
Steven A. Kandarian
Chairman of the Board, President and Chief Executive Officer
MetLife, Inc.
200 Park Avenue
New York, NY 10166

Re: MetLife, Inc.
Form 10-K for the Fiscal Year Ended December 31 , 201 1
Filed February 2 8, 201 2
Form 10-Q for the Quarterly Period Ended March 31, 2012
Filed May 8, 2012
File No. 001-15787

Dear Mr. Kandarian :

We have reviewed your filing s and have the following comments.   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 keys your
response s to our c omment s.

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

Form 10 -K for the Year Ended December 31, 2011

Item 1A.  Risk Factors
Change in market interest rates may significantly aff ect our profitability, page 45

1. You state that sustained periods of low or declining interest rates may adversely affect
your results of operations, financial position and cash flows.  Please provide us proposed
disclosure to be included, in MD&A, in futur e periodic reports that discloses the expected
effects of this known trend or uncertainty on your future financial position, results of
operations and cash flows. To the extent that information about the amount you expect to
have to reinvest new cash flows  or to reinvest at lower rates, or information about the
amount of products you are committed at guaranteed rates is necessary to understand

Steven A. Kandarian
MetLife, Inc.
June 7, 2012
Page 2

 these effects, please include these amounts and their effects in your proposed disclosure
to the extent known.

Item 7. Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Executive Summary
Year Ended December 31, 2011 compared with the Year Ended December 31, 2010, page 80

2. You state that all amounts discussed in this section are net of income tax.  Tell us why
you believe analyzing revenues and expenses net of income taxes complies with Item 303
of Regulation S -K.  For example, you discuss a change of $3.3 billion of net derivative
gains (losses) from 2010 to 2011 when the stateme nt of operations shows a change of
$5.1 billion.

Policyholder Liabilities
Policyholder Account Balances, page 163

3. You state that most of the annuity retirement products have a minimum guaranteed rate
between  1.0 percent and  4.0 percent.  Please provide us proposed disclosure to be
included in future periodic filings that quantifies the distribution of annuity and universal
life account values within this range.

Form 10 -Q for the Quarterly Period Ended March 31, 2012
Management’s Discussion and Analysis,  page 128

4. Net derivative losses in the three months ended March 31, 2012 were $2 billion
compared to losses of $315 million in the three months ended March 31, 2011.  Net
derivative gains/(losses) recognized are very volatile from quarter to quarter, for
example, you recognized net derivatives gains of $4.1 billion in the three months ended
September 30, 2011 and net derivatives gains of $591 million in the three months ended
December 31, 2011  and then net derivatives losses of $2 billion in the first quar ter of
2012 .  You disaggregate the 2012 $3.8 billion net loss  on freestanding derivatives on
page 55 by 15 different types of derivatives.  You state in MD&A that the 2012 net
derivative losses are attributable mainly to “the impact of equity market moveme nts and
decreased volatility, and rising long -term interest rates”   This explanation appears overly
general  and not useful .
 Please provide us proposed disclosure to be included in future periodic report s to
more fully explain the causes of the net losses  in 2012.  You should consider using
tables similar to those discussing sensitivity analysis beginning on page 180 to
explain how the net derivatives gains/losses provide an economic hedge.

Steven A. Kandarian
MetLife, Inc.
June 7, 2012
Page 3

 Also e xplain , in proposed disclosure to be included in future peri odic reports , the
$508 million net loss on Level 3 equity market contracts disclosed on page 78 .  Please
include disclosure for the changes to the significant unobservable inputs of volatility
and offered quotes, why they changed and why you believe the in puts used at
December 31, 2011 that resulted in $601 million of net gains in 2011 (page 321 of
Form 10 -K) were reasonable.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing s to be certain that the filing s include 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 the 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 s;
 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 s; and
 the company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any pers on under the federal securities laws of the United States.

Please contact James Peklenk, Staff Accountant, at (202) 551 -3661 or Lisa Vanjoske,
Assistant Chief Accountant, at (202) 551 -3614 if you have any questions  regarding the
comments .  In this regard,  do not hesitate to contact me at (202) 551 -3679.

Sincerely,

/s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief Accountant