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LETTER TO THE S.E.C.

March 1, 2007

Mr. James B. Rosenberg

Senior Assistant Chief Accountant

United States Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

              RE:

    MetLife, Inc.

Form 10-K for fiscal year ended December 31, 2005

File No. 1-15787

Dear Mr. Rosenberg:

Subsequent to our letter dated December 21, 2006, where we cleared Comments #1 and #2 to your
letter dated September 25, 2006 (the “Comment Letter”) regarding MetLife, Inc.’s (the “Company’s”)
Annual Report on Form 10-K for the fiscal year ended December 31, 2005 (the “2005 Form
10-K”) we have had further discussions with Frank Wyman of the Staff regarding the Company’s
contractual obligations disclosure, the subject of Comment #3. This letter sets forth our final
response to Comment #3, including an example of the contractual obligations disclosure to which we
have agreed. As it relates to Comments #1 and #2 we have also included examples of the disclosures
to which we agreed during our discussions resolving the comments.

Comment #1

Summary of Critical Accounting Estimates, page 60

    1.

    We believe your disclosure could be improved to better explain the
judgments and uncertainties in applying critical accounting estimates for DAC and VOBA
and the likelihood that materially different amounts would be reported under different
conditions or using different assumptions. Please provide us in disclosure-type format
the financial statement impact that reasonably likely changes in key assumptions
underlying the December 31, 2005 estimates may have on financial position and results
of operations. Refer to Section V of Financial Reporting Release No. 72.

Response to Comment #1

We will add the expanded disclosure with respect to DAC and VOBA, as set forth in Exhibit 1, to the
Company’s 2006 Annual Report on Form 10-K (the “2006 Form 10-K”). “Item 7, Management’s Discussion
and Analysis of Financial Condition and Results of Operations — Summary of Critical Accounting
Estimates.”

For purposes of the Company’s Form 10-Q filing for the quarter ended September 30, 2006 we revised
our DAC and VOBA critical estimates disclosure to include a substantial portion of the expanded
information. Such disclosures were included within “Item 2, Management’s Discussion and Analysis
of Financial Condition and Results of Operations — Summary of Critical Accounting Estimates.”

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Comment #2

Discussion of Results, page 67

    2.

    Given the apparent significance of “interest spreads” to your operating results for
the institutional and individual segments, we believe that your disclosure could be
improved. Please provide to us, in disclosure-type format, the following information
for each of these segments.

    •

    Quantify the dollar impact on operating results that corresponds to the
percentage “interest spread” for each period presented.

    •

    Describe how you compute “yield on invested assets” and quantify the
resulting dollar amount used to determine the “interest spread” for each period
presented.

    •

    Describe how you compute “interest rate used to credit on certain
liabilities” and quantify the resulting dollar amount used to determine the
“interest spread” for each period presented.

    •

    Describe the factors that you considered in determining the expected range
for “interest spreads” for each period presented. Explain why you used
different “interest spreads” for 2004 in your comparisons of Institutional
segment operating results for 2005/2004 and 2004/2003.

    •

    Explain more specifically the factors underlying the change in
“interest spread” and the variance between the expected and actual spreads for
each period presented. We note that for non-medical health & other business,
the actual spread was 3.38% for 2005 and 3.06% for 2004 as compared to the
expected spread range of 1.3 to 1.6% at December 31, 2005 and 1.3 to 1.5% at
December 31, 2004.

Response to Comment #2

In responding to your comment, we will revise our disclosure within the Institutional and
Individual segments by removing references to interest spread percentages (Income from Continuing
Operations section of MD&A) and replacing them with a more comprehensive disclosure of the two
principal components of the Company’s interest margins. This revised disclosure will include the
impact that the changes in invested assets and the change in the related investment yields have on
net investment income (Revenues section of MD&A) as well as the impact that changes in policyholder
liabilities and their crediting rates have on interest credited (Expenses section of MD&A). We
believe this format will enhance the understanding of the linkage between the income statement
lines and their associated contribution to interest margins.

We will implement this revised format in the 2005 and 2006 MD&As of the 2006 Form 10-K. For
illustrative purposes, attached as Exhibits 2 and 3 are the Institutional and Individual segment
MD&As, respectively, from the 2005 Form 10-K, revised to reflect the new format.

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Comment #3

Liquidity and Capital Resources, Contractual Obligations, page 94

    3.

    You state that “liabilities for future policy benefits of $82.4 billion and
policyholder account balances of $113.4 billion both at December 31, 2005 have been
excluded from the table” because in general the insurable event (e.g., death or
disability) or triggering event has not yet occurred. However, you also make
extensive use of asset/liability matching processes, whereby you “regularly
reevaluate estimates used in determining the approximate amounts and timing of
payments to and or on behalf of policy holders for insurance liabilities.” These
capabilities appear to indicate that you regularly estimate the information
described in Item 303(a)(5) of Regulation S-K. Please provide us a revised table
including estimates for the amount and timing of payments related to the excluded
amounts or explain more specifically for each product line why you are unable to
provide this information in the table of contractual obligations.

Response to Comment #3

We will expand our contractual obligations disclosure in the 2006 Form 10-K as set forth in Exhibit
4. The format of this disclosure will be included in our 2006 Form 10-K.

If we may be of assistance in answering any questions that may arise in connection with the Staff’s
review of our response letter, please call me at (212) 578-8846.

* * * * *

Sincerely,

/s/ Joseph J. Prochaska, Jr.

Joseph J. Prochaska, Jr.

Executive Vice President and

Chief Accounting Officer

    cc:

    C. Robert Henrikson

William J. Wheeler

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Exhibit 1

Deferred Policy Acquisition Costs and Value of Business Acquired

The Company incurs significant costs in connection with acquiring new and renewal insurance
business. The costs that vary with and relate to the production of new business are deferred as
DAC. VOBA is an intangible asset that reflects the estimated fair value of in-force contracts in a
life insurance company acquisition. VOBA represents the portion of the purchase price that is
allocated to the value of the right to receive future cash flows from the business in force at the
acquisition date. The recovery of DAC and VOBA is dependent upon the future profitability of the
related business. DAC and VOBA are aggregated in the financial statements for reporting purposes.

DAC for property and casualty insurance contracts is amortized on a pro rata basis over the
applicable contract term or reinsurance treaty.

DAC and VOBA on life insurance or investment type contracts are amortized in proportion to gross
premiums, gross margins or gross profits, depending on the type of contract as described below.

The Company amortizes DAC and VOBA related to non-participating and non-dividend-paying traditional
contracts (term insurance, non-participating whole life insurance, non-medical health insurance,
and traditional group life insurance) over the entire premium paying period in proportion to the
present value of actual historic and expected future gross premiums. The present value of expected
premiums is based upon the premium requirement of each policy and assumptions for mortality,
morbidity, persistency, and investment returns at policy issuance, or policy acquisition as it
relates to VOBA that include provisions for adverse deviation and are consistent with the
assumptions used to calculate future policyholder benefit liabilities. These assumptions are not
revised after policy issuance or acquisition unless the DAC or VOBA balance is deemed to be
unrecoverable from future expected profits. Absent a premium deficiency, variability in
amortization after policy issuance or acquisition is caused only by variability in premium volumes.

The Company amortizes DAC related to participating, dividend-paying traditional contracts over the
estimated lives of the contracts in proportion to actual and expected future gross margins. The
Company has no VOBA associated with such contract types. The future gross margins are dependent
principally on investment returns, policyholder dividend scales, mortality, persistency, expenses
to administer the business, creditworthiness of reinsurance counterparties, and certain economic
variables, such as inflation. For participating contracts (dividend paying traditional contracts
within the closed block) future gross margins are also dependent upon changes in the policyholder
dividend obligation. Of these factors, the Company anticipates that investment returns, expenses,
persistency, and other factor changes and policyholder dividend scales are reasonably likely to
impact significantly the rate of DAC amortization. Each reporting period, the Company updates the
estimated gross margins with the actual gross margins for that period. When the actual gross
margins exceed the previously estimated gross margins, DAC amortization will increase, resulting in
a current period charge to earnings. The opposite result occurs when the actual gross margins are
below the previously estimated gross margins. Each reporting period, the Company also updates the
actual amount of business in-force, which impacts expected future gross margins.

The Company amortizes DAC and VOBA related to fixed and variable universal life contracts and fixed
and variable deferred annuity contracts over the estimated lives of the contracts in proportion to
actual and expected future gross profits. The amount of future gross profits is dependent
principally upon returns in excess of the amounts credited to policyholders, mortality,
persistency, interest crediting rates, expenses to administer the business, creditworthiness of
reinsurance counterparties, the effect of any hedges used, and certain economic variables, such as
inflation. Of these factors, the Company anticipates that investment returns, expenses, and
persistency are reasonably likely to impact significantly the rate of DAC and VOBA amortization.
Each reporting period, the Company updates the estimated gross profits with the actual gross
profits for that period. When the actual gross profits exceed the previously estimated gross
profits, DAC and VOBA amortization will increase, resulting in a current period charge to earnings.
The opposite result occurs when the actual gross profits are below the previously estimated gross
profits. Each reporting period, the Company also updates the actual amount of business remaining
in-force, which impacts expected future gross profits.

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Separate account rates of return on variable universal life contracts and variable deferred annuity
contracts affect in-force account balances on such contracts each reporting period. Returns that
are higher than the Company’s long-term expectation produce higher account balances, which
increases the Company’s future fee expectations and decreases future benefit payment expectations
on minimum death benefit guarantees, resulting in higher expected future gross profits. The
opposite result occurs when returns are lower than the Company’s long-term expectation. The
Company’s practice to determine the impact of gross profits resulting from returns on separate
accounts assumes that long-term appreciation in equity markets is not changed by short-term market
fluctuations, but is only changed when sustained interim deviations are expected. We monitor these
changes and only change the assumption when our long-term expectation changes. The effect of an
increase/(decrease) by 100 basis points in the assumed future rate of return is reasonably likely
to result in a decrease/(increase) in the DAC and VOBA balances of approximately $70 million for
this factor.

The Company also reviews periodically other long-term assumptions underlying the projections of
estimated gross margins and profits. These include investment returns, policyholder dividend
scales, interest crediting rates, mortality, persistency, and expenses to administer business.
Management annually updates assumptions used in the calculation of estimated gross margins and
profits which may have significantly changed. If the update of assumptions causes expected future
gross margins and profits to increase, DAC and VOBA amortization will decrease, resulting in a
current period increase to earnings. The opposite result occurs when the assumption update causes
expected future gross margins and profits to decrease.

Over the past two years, the Company’s most significant assumption updates resulting in a change to
expected future gross margins and profits and the amortization of DAC and VOBA have been updated
due to revisions to expected future investment returns, expenses, in-force or persistency
assumptions and policyholder dividends on contracts included within the Individual Business
segment. We expect these assumptions to be the ones most reasonably likely to cause significant
changes in the future. Changes in these assumptions can be offsetting and we are unable to predict
their movement or offsetting impact over time.

The following chart illustrates the effect on DAC and VOBA within the Company’s Individual segment
of changing each of the respective assumptions during the years ended December 31, 2005 and 2004:

    2005

    2004

    Investment Return

    xx

    xx

    Expense

    xx

    xx

    In-force/Persistency

    xx

    xx

    Policyholder Dividends and Other

    xx

    xx

    Total

    xx

    xx

As of December 31, 2005 and 2004 DAC and VOBA were $19.7 billion and $14.3 billion, respectively.

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Exhibit 2

YEAR ENDED DECEMBER 31, 2005 COMPARED WITH THE YEAR ENDED DECEMBER 31, 2004 — INSTITUTIONAL

Income from continuing operations increased by $92 million, or 7%, to $1,400 million for the year
ended December 31, 2005 from $1,308 million for the comparable 2004 period. The acquisition of
Travelers accounted for $73 million of this increase, which includes $57 million, net of income
taxes, of net investment losses. Excluding the impact of the Travelers acquisition, income from
continuing operations increased by $19 million, or 1%, from the comparable 2004 period.

An increase in interest margins of $124 million, net of income taxes, compared to the prior year
period contributed to the increase in income from continuing operations. Management attributes this
increase primarily to the retirement & savings and the non-medical health & other businesses of $81
million and $44 million, both net of income taxes, respectively. Interest margin is the difference
between interest earned and interest credited to policyholders. Interest earned approximates net
investment income on investable assets attributed to the segment with minor adjustments related to
the consolidation of certain separate accounts and other minor non-policyholder elements. Interest
credited is the amount attributed to insurance products, recorded in policyholder benefits, and the
amount credited to policy