SecProbe.io

Mail Stop 4 546
October 3 , 2016

Via E -mail
Mr. John C. R. Hele
Executive Vice President and Chief Financial  Officer
MetLife, Inc.
200 Park Avenue
New York, New York  10166 -0188

Re: MetLife, Inc.
 Form 8 -K
 Filed August 3, 2016
 File No. 001-15787

Dear Mr. Hele:

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

Please respond to these comments within 10 business days by providing the requested
information or advise us as soon as possible when you will respond.  If y ou do not believe a
comment applies to your facts and circumstances, please tell us why in your response .

After reviewing your response to these comments, we may have additional comments.

Exhibit 99.1:  News release dated August 3, 2016
Second Quarter R esults, page 1

1. Your comparison of non -GAAP results to prior periods without a corresponding
discussion of GAAP results causes your non -GAAP measures to be more prominent than
the most directly comparable GAAP measures.  Please include a comparison of your
GAAP results to those of prior periods in your next earnings release. See Question 102.10
of the updated Non-GAAP Compliance and Disclosure Interpretations  issued on May 17,
2016.

Second Quarter 2016 Summary, page 2

2. Your discussion at the top of page 3 lacks  mention o f the most comparable GAAP
measures, which causes your non -GAAP measures to be more prominent than the most
directly comparable GAAP measures.   Please provide a discussion of the most

Mr. John C. R. Hele
MetLife, Inc.
Octo ber 3, 201 6
Page 2

 comparable GAAP measures in your next earnings release.   See Question 102.10 of the
updated Non-GAAP Compliance and Disclosure Interpretations  issued on May 17, 2016 .

Non-GAAP and Other Financial Disclosures, page 6

3. In your next earnings release, please provide a more substantive , and concise,  discussion
of how each of your non -GAAP measures is useful to investors .  Please provide us with
your proposed changes in your response letter  for each of the measures that you expect to
present in the next earnings release .

Consolidated Statements of Operating Earnings Available to Common Shareholders (Unaudited)

4. You present  a full income statement of non -GAAP measures, which causes your non -
GAAP measures to be more prominent than the most directly comparable GAAP
measures.  Please remove your full income state ment of non -GAAP measures in your
next earnings release.  See Question 102.10 of the updated Non-GAAP Compliance and
Disclosure Interpretations  issued on May 17, 2016 .

5. Please revise your next earnings release to begin  your reconciliation s with GAAP  results
rather than non-GAAP results .  See Question 102.10 of the updated Non-GAAP
Compliance and Disclosure Interpretations  issued on May 17, 2016.

6. Please disclose how you calculated the income tax benefits of your non -GAAP
adjustments in your next earning s release.   See Question 102.11 of the updated Non-
GAAP Compliance and Disclosure Interpretations  issued on May 17, 2016 .

Reconciliation to Premiums , Fees and Other Revenues (Unaudited)

7. You present adjustments to premiums, fees , and other revenues but do not explain what
these adjustments are or quantify them.  Please tell us what these adjustments represent
and provide additional disclosure in your future earnings releases.   This comment also
applies to your “other adjustments to revenues” and “other adjustment to expense” in
your reconciliation to revenues and expenses .

 We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s all 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 t o our commen ts, please provide  a written statement from the company
acknowledging that:

 the company is responsible for the adequacy and ac curacy of the disclosure in the filing;
 staff comment s or changes to disclosu re in response to staff comment s do not foreclose
the Commission from taking any action with respect to the filing; and

Mr. John C. R. Hele
MetLife, Inc.
Octo ber 3, 201 6
Page 3

  the compa ny may not assert the staff comment s 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 Mark Bru nhofer, Senior Staff Accountant, at (202) 551 -3638 or Sharon
Blume, Accounting Branch Chief, at (202) 551 -3474 if you have questions regarding the
comment s.  In this regard, do not hesitate to contact me at (202) 551 -3426.

Sincerely,

/s/ Angela M. Connell

Angela M. Connell
Accounting Branch Chief
Office of Healthcare and Insurance