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RESPONSE LETTER

October 26, 2007

Mr. Tim Buchmiller, Esq.

Senior Attorney

United States Securities and Exchange Commission

450 Fifth Street, NW

Washington, D.C. 20549

         Re:

    MetLife, Inc.

Definitive Proxy Statement

Filed March 26, 2007

File No. 001-015787

Dear Mr. Buchmiller:

Further to our conversation on Wednesday, September 12, 2007, this letter sets forth the response
of MetLife, Inc. (the “Company”) to the comments contained in your letter dated August 21, 2007
(the “Comment Letter”) regarding the Company’s Definitive Proxy Statement filed on March 26, 2007
(the “Proxy Statement”).

2006 Director Compensation Table, page 22

    1.

    Disclose the assumptions made in the valuation of the stock awards by reference to a discussion of
those assumptions in your financial statements, footnotes to the financial statements or
discussion in Management’s Discussion and Analysis. Refer to the Instruction to Item 402(k)
of Regulation S-K.

Response to Comment #1

As stated on page 23 of the Proxy Statement, 50% of each non-management director’s 2006 annual
retainer of $225,000 was payable in shares of the Company’s common stock. Those stock awards were
immediately vested (see page 22, footnote 3, of the Proxy Statement), and the dollar amount of such
awards was based on the grant date fair market value of the awards. The Company did not include a
cross-reference to assumptions made in the valuation of the stock awards reported in the 2006
Director Compensation Table because no assumptions were necessary. In response to the staff’s
comments, however, the Company will disclose in future proxy statements that the grant date fair
market value represents the number of shares awarded multiplied by the closing

price of the Company’s common stock on the date of grant. The Company will also disclose what that
closing price was on the date of grant.

Compensation Discussion and Analysis, page 29

    2.

    The Compensation Discussion and Analysis should be sufficiently precise to capture material
differences in compensation policies with respect to individual named executive officers.
Refer to Section II.B.1 of Commission Release No. 33-8732A. In this regard, we note the
significant disparity in the value of the stock and option awards to Messrs. Henrikson and
Benmosche and the non-equity incentive plan compensation awarded to Mr. Henrikson as compared
to the similar awards to your other named executive officers. Given these disparities,
please include a more detailed discussion of how and why the compensation of your chief
executive officers has materially differed from that of the other named executive officers.
If policies or decisions applicable to a named executive officer are materially different than
those that apply to the other officers, those policies or decisions should be discussed on an
individualized basis.

Response to Comment #2

The practices and processes that the Company’s Compensation Committee (the “Committee”) followed in
determining the compensation of Messrs. Henrikson and Benmosche were substantially the same as
those it followed in determining the compensation of the other executives. In determining the
chief executive officers’ compensation, the Committee considered their broader responsibilities and
higher levels of accountability, compared to the Company’s other executives. It also considered
market data on chief executive officer compensation. As a result, the Committee approved a higher
level of total compensation for Mr. Henrikson and Mr. Benmosche than for other Named Executive
Officers. When applicable, the Company will disclose in future proxy statements that the
application of its practices and processes resulted in higher compensation for its Chief Executive
Officer than for other Named Executive Officers due to differences in the level of responsibilities
and accountability associated with the chief executive officer position as well as competitive
market data.

    3.

    We note from your disclosure under “Setting Compensation” on page 31 that you establish
specific quantitative and qualitative goals at the beginning of each year. Your Compensation
Discussion and Analysis appears, however, only to discuss the targets and goals for the
elements of your compensation packages for 2006. Please expand your Compensation Discussion
and Analysis to include a discussion of the goals you have set for the current year and
provide an analysis of how such goals will affect the calculation of amounts awarded to your
named executive officers under the various elements of your compensation program. Refer to
the text of Securities Act Release 33-8732A, marked by footnote 86. Include in your
discussion an analysis of what growth levels in your financial and operational metrics the
goals are intended to incentivize.

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Response to Comment #3

We do not believe the Company was required to include a discussion of its 2007 performance goals in
the Proxy Statement. Instruction 2 to Item 402(b) of Regulation S-K indicates that the
Compensation Discussion and Analysis should cover actions regarding executive compensation that
were taken after the registrant’s last fiscal year if those actions affected the prior year’s
compensation, or if such a discussion is otherwise necessary to give context to the disclosure of
the prior year’s compensation.

The Company’s 2007 goals did not impact its Named Executive Officers’ compensation for 2006. As a
result, disclosure of those goals would not have been necessary to put the 2006 compensation of the
Named Executive Officers into context. The Company will include a discussion in its 2008 proxy
statement about how the Company’s goals for 2007 related to 2007 compensation for the Named
Executive Officers, similar to the discussion contained in the Proxy Statement regarding 2006 goals
and their effect on 2006 compensation. In addition, the Company will also explain in future proxy
statements its purposes in establishing performance goals, including directing and motivating
behavior that will meet corporate performance objectives. The Company will also affirm that
individual goals reflect, and are aligned with, those corporate objectives.

    4.

    You disclose that in formulating its recommendations, the Compensation Committee reviews
individual performance for the year measured against previously established goals. Please
discuss how the various elements of compensation are structured and implemented to reflect
each of the named executive officer’s individual performance and contribution to the
achievement of the Company’s results when determining the form and amounts of compensation to
award. You should address the nature of the personal goals in reasonably complete detail and
describe the level of difficulty, or ease, associated with achieving those goals. Refer to
Item 402(b)(2)(vii) of Regulation S-K.

Response to Comment #4

The Company uses a Total Compensation structure (as defined on page 29 of the Proxy Statement) that
consists of base salary and annual and long-term incentive award opportunities. The Committee
recommends Total Compensation based on its review of Company, business unit, and individual
performance, as well as competitive market data. The Committee’s review is a substantive
assessment of these elements, and one in which it uses its judgment to arrive at appropriate Total
Compensation in light of all of these factors. In response to the staff’s comments, the Company
will disclose in future proxy statements that particular elements of compensation are not
structured to relate to separate individual goals or performance, but rather that each Named
Executive Officer’s Total Compensation is designed to reflect corporate performance, business unit
performance, the Committee’s assessment of individual performance, and competitive market data.
The Company will also continue to provide information in future proxy

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statements on each element of compensation, as described on pages 32-33 of the Proxy Statement.

While long-term incentive award opportunities are not determined on a formulaic basis, actual
payout values of those awards are determined by formula. The number of performance shares actually
payable depends on the Company’s performance as determined by a formula described on pages 44-45 of
the Proxy Statement. Similarly, the ultimate value of stock options depends exclusively on
increases in the price of the Company’s common stock from the date of grant through the date they
are exercised.

Benchmarking Compensation, page 30

    5.

    Given that the Compensation Committee has determined that Total Compensation opportunities
are competitive if they fall between the 75th percentile of insurance companies in
the comparator group and the 50th percentile of the entire comparator group, please
specify how each element of compensation you provide to the named executive officers relates
to the data you have analyzed from the companies in the comparator group, and include a
discussion of where you target each element of compensation against the peer companies and
where actual payments under each element of compensation actually fell within the targeted
parameters. To the extent actual compensation was outside of a targeted range, please discuss
why. Refer to Item 402(b)(2)(xiv) of Regulation S-K.

Response to Comment #5

The Company does not benchmark compensation on a separate element-by-element basis. Rather, it
employs a Total Compensation structure using competitive total compensation data from our
comparator group of companies (listed on page 31 of the Proxy Statement). In recommending Total
Compensation opportunities, the Compensation Committee considers the benchmark range — between the
75th percentile of the insurance companies and the 50th percentile of the
entire comparator group for positions of comparable value and importance — as one factor, along
with the assessment of individual, business unit, and company performance it makes, using its
judgment.

Components of Compensation and Benefits, page 32

    6.

    Please discuss and analyze how each of the various elements of compensation fit into your
overall compensation objectives and affect decisions regarding other elements under your
compensation program. See Item 402(b)(1)(vi) of Regulation S-K.

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Response to Comment #6

We note your comment and believe that the Proxy Statement is responsive. For example, pages 32 and
33 of the Proxy Statement provide information on each element of compensation and how it relates to
the Company’s Total Compensation framework. That disclosure discusses the purposes for paying each
element of Total Compensation. In addition, on page 29 the Proxy Statement describes how each
element of compensation fits into the Company’s Total Compensation program and affects decisions
regarding other elements of that program.

Finally, the Proxy Statement also describes on pages 29 and 30 how the Company’s compensation
program is designed to meet its objectives.

In response to the staff’s comments, however, the Company will disclose in future proxy statements
that decisions on salary, AVIP, and long-term incentives (including options and performance shares)
impact decisions on the other elements because MetLife utilizes a competitive Total Compensation
structure and decisions on any one of these three elements are not viewed in isolation. However,
decisions on these elements do not impact decisions on other compensation elements such as
retirement or other benefits, which are determined on the basis of programs that apply to
substantially all associates. As a result, decisions about retirement and other benefits do not
vary based on decisions about an individual’s salary, AVIP, or long-term incentive awards.

Annual Incentive Awards, page 32

    7.

    Your disclosure indicates that the bonus payments under the Annual Variable Incentive Plan
are based on company, business unit and individual performance and that the maximum dollar
amount available under the AVIP awards is based on a formula that consists of two performance
measures: operating earnings and return on equity. Similarly, we note that the performance
share units become payable in shares of your common stock depending on whether “specified
performance goals” are met. Your Compensation Discussion and Analysis, however, does not
provide adequate discussion and analysis of the quantitative or qualitative aspects of the
goals to be achieved in order for your executive officers to earn the incentive compensation
indicated. Please disclose the specific quantitative and qualitative aspects of the
performance objectives used to determine incentive amounts. Include in your analysis a
discussion of how the specific levels were determined and what levels of performance such
levels were intended to incentivize. See Item 402(b)(2)(v) and Instruction 2 to Item 402(b).
To the extent that you believe that disclosure of the information could be excluded under
Instruction 4 to Item 402(b), please provide us with a detailed explanation supporting your
conclusion. To the extent that it is appropriate to omit specific targets or performance
objectives, you are required to provide appropriate disclosure pursuant to Instruction 4 to
Item 402(b) of Regulation S-K. Refer also to Question 3.04 of the Item 402 of Regulation S-K
Interpretation available on our website at www.sec.gov. In discussing how difficult or
likely it will be for the registrant to achieve the target levels or other factors, you should
provide

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    as much detail as necessary without disclosing information that poses a reasonable risk of
competitive harm.

Response to Comment #7

Consistent with the requirements of Item 402(e) of Regulation S-K, performance objectives related
to the 2006 AVIP and performance share award grants during 2006 were disclosed in the narrative
following the Grants of Plan-Based Awards table. The performance goals that must be met in order
for performance shares granted in 2006 to become payable are disclosed in specific detail on page
45 of the Proxy Statement. The performance goals that are used to determine the maximum dollar
amounts available for all AVIP awards do not determine the
amount of any award earned by any individual, including the Named Executive Officers, and therefore
no disclosure regarding those goals would be useful in understanding individual awards. Further,
the formula for determining the maximum AVIP award payable to each individual Named Executive
Officer is disclosed on page 44 of the Proxy Statement:

    In December 2005, the Compensation Committee made Mr. Henrikson and Mr. Benmosche each
eligible for an annual incentive payment for 2006 performance under AVIP in an amount of up
to 1% of the Company’s net operating income, but not more than $10 million, which is the
maximum award under AVIP. For 2006, each other Named Executive Officer was eligible for an
AVIP award in an amount up to 0.5% of the Company’s net operating income, but not more than
the $10 million maximum award under AVIP. Ten million dollars was less than 0.5% of the
Company’s net operating income.

This discussion of performance objectives was not repeated in the Compensation Discussion and
Analysis in accordance with Instruction 3 to Item 402(b) of Regulation S-K, which states that the
Compensation Discussion and Analysis should avoid repetition of the more detailed information set
forth in the tables and narrative disclosures that follow. We address the staff’s comment as it
applies to individual performance goals and award determinations in our response to comment #8.

    8.

    We note minimal analysis of how the actual payouts under the Annual Variable Incentive Plan
were determined. In this regard, we note your disclosure that company, business unit and
individual performance goals are assessed by the Compensation Committee in awarding this form
of compensa