SecProbe.io

CORRESP
1
filename1.htm

corresp

1095 Avenue of the Americas

New York, NY 10036

Peter M. Carlson

Executive Vice President &

Chief Accounting Officer

April 9, 2010

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 the Fiscal Year Ended December 31, 2009

File No. 001-15787

Dear Mr. Rosenberg:

This letter sets forth the response of MetLife, Inc. (the “Company”) to the comments contained in
your letter dated March 29, 2010 regarding the Company’s Annual Report on Form 10-K for the year
ended December 31, 2009 (“2009 Form 10-K”).

In response to your comments, we have reproduced your comments below in boldface, italic type and
set forth our response immediately below each comment.

With regard to your repurchase agreements, please tell us whether you account for any of those
agreements as sales for accounting purposes in your financial statements. If you do, we ask that
you:

    •

    Quantify the amount of repurchase agreements qualifying for sales accounting at each
quarterly balance sheet date for each of the past three years.

    •

    Quantify the average quarterly balance of repurchase agreements qualifying for sales
accounting for each of the past three years.

    •

    Describe all the differences in transaction terms that result in certain of your
repurchase agreements qualifying as sales versus collateralized financings.

    •

    Provide a detailed analysis supporting your use of sales accounting for your repurchase
agreements.

    •

    Describe the business reasons for structuring the repurchase agreements as sales
transactions versus collateralized financings. To the extent the amounts
accounted for as sales transactions have varied over the past three years, discuss the reasons
for quarterly changes in the amounts qualifying for sales accounting.

    •

    Describe how your use of sales accounting for certain of your repurchase agreements impacts
any ratios or metrics you use publicly, provide to analysts and credit rating agencies,
disclose in your filings with the SEC, or provide to other regulatory agencies.

    •

    Tell us whether the repurchase agreements qualifying for sales accounting are concentrated
with certain counterparties and/or concentrated within certain countries. If you have any
such concentrations, please discuss the reasons for them.

    •

    Tell us whether you have changed your original accounting on any repurchase agreements
during the last three years. If you have, explain specifically how you determined the
original accounting as either a sales transaction or as a collateralized financing transaction
noting the specific facts and circumstances leading to this determination. Describe the
factors, events or changes which resulted in your changing your accounting and describe how
the change impacted your financial statements.

Management Response:

The Company accounts for transactions involving sales of securities under agreements to repurchase
(“repurchase agreements”) as collateralized financing transactions. There were no repurchase
agreements entered into by the Company for the three years ended December 31, 2009 that were
accounted for as sales in the Company’s consolidated financial statements.

For those repurchase agreements you account for as collateralized financings, please quantify the
average quarterly balance for each of the past three years. In addition, quantify the period end
balance for each of those quarters and the maximum balance at any month-end. Explain the causes
and business reasons for significant variances among these amounts.

Management Response:

As discussed in Note 11, Long-term and Short-term Debt, in Notes to the Consolidated Financial
Statements of the Company’s 2009 Form 10-K, MetLife Bank, N.A. (“MetLife Bank”) is a member of the
Federal Home Loan Bank of New York (“FHLB of NY”). As a member of FHLB of NY, MetLife Bank has
entered into certain agreements categorized as repurchase agreements in exchange for cash and has
granted FHLB of NY a blanket lien on certain of MetLife Bank’s residential mortgages, mortgage
loans held-for-sale, commercial mortgages and mortgage-backed securities to collateralize
obligations under the repurchase agreements.

2

The quarter-end balance, average quarterly balance (calculated based on month-end balances) and
maximum balance at any month-end for each of the past three years relating to these agreements is
as follows (in millions):

    Quarter-end

    Average

    Maximum

    Quarter-end

    Balance

    Quarterly Balance

    Month-end Balance

    3/31/07

    $
    1,088

    $
    1,028

    $
    1,088

    6/30/07

    $
    963

    $
    1,007

    $
    988

    9/30/07

    $
    1,013

    $
    1,001

    $
    1,013

    12/31/07

    $
    1,213

    $
    1,113

    $
    1,213

    3/31/08

    $
    1,212

    $
    1,185

    $
    1,212

    6/30/08

    $
    1,212

    $
    1,226

    $
    1,267

    9/30/08

    $
    1,987

    $
    1,406

    $
    1,987

    12/31/08

    $
    1,757

    $
    2,166

    $
    2,822

    3/31/09

    $
    3,812

    $
    2,569

    $
    3,812

    6/30/09

    $
    3,842

    $
    3,288

    $
    3,842

    9/30/09

    $
    2,382

    $
    2,797

    $
    2,592

    12/31/09

    $
    2,431

    $
    2,219

    $
    2,431

In August 2008, MetLife Bank acquired a mortgage origination and servicing business and increased
its borrowings from FHLB of NY as a component of funding the business. Subsequent variances in
quarter-end and average quarterly balances are the result of changes in funding requirements and
the availability of alternative sources of short term funding.

In addition, certain of MetLife’s international businesses enter into repurchase transactions in
the ordinary course of business which are accounted for as collateralized financings. The
quarter-end balance, average quarterly balance (calculated based on month-end balances) and maximum
balance at any month-end for each of the past three years relating to these agreements is as
follows (in millions):

3

    Quarter-end

    Average

    Maximum

    Quarter-end

    Balance

    Quarterly Balance

    Month-end Balance

    3/31/07

    $
    20

    $
    18

    $
    20

    6/30/07

    $
    15

    $
    15

    $
    15

    9/30/07

    $
    21

    $
    14

    $
    21

    12/31/07

    $
    10

    $
    12

    $
    16

    3/31/08

    $
    0

    $
    3

    $
    0

    6/30/08

    $
    24

    $
    20

    $
    38

    9/30/08

    $
    42

    $
    23

    $
    42

    12/31/08

    $
    13

    $
    14

    $
    13

    3/31/09

    $
    0

    $
    4

    $
    0

    6/30/09

    $
    17

    $
    5

    $
    17

    9/30/09

    $
    14

    $
    8

    $
    14

    12/31/09

    $
    54

    $
    31

    $
    54

In addition, please tell us:

    •

    Whether you have any securities lending transactions that you account for as sales pursuant
to the guidance in ASC 860-10. If you do, quantify the amount of these transactions at each
quarterly balance sheet date for each of the past three years. Provide a detailed analysis
supporting your decision to account for these securities lending transactions as sales.

Management Response:

During the three years ended December 31, 2009, there were no securities lending transactions that
the Company has accounted for as sales in its consolidated financial statements.

As discussed in Note 1, Business, Basis of Presentation and Summary of Significant Accounting
Policies and Note 3, Investments, in Notes to the Consolidated Financial Statements of the
Company’s 2009 Form 10-K, securities lending transactions, whereby blocks of securities, which are
included in fixed maturity securities and short-term investments, are loaned to third parties, are
treated as financing arrangements and the associated liability is recorded at the amount of cash
received.

4

    •

    Whether you have any other transactions involving the transfer of financial assets with an
obligation to repurchase the transferred assets, similar to repurchase or securities lending
transactions that you account for as sales pursuant to the guidance in ASC 860. If you do,
describe the key terms and nature of these transactions and quantify the amount of the
transactions at each quarterly balance sheet date for the past three years.

Management Response:

The Company does not have any other transactions involving the transfer of financial assets with an
obligation to repurchase the transferred assets, similar to repurchase or securities lending
transactions that are accounted for as sales.

    •

    Whether you have offset financial assets and financial liabilities in the balance sheet
where a right of setoff — the general principle for offsetting — does not exist. If you
have offset financial assets and financial liabilities in the balance sheet where a right of
setoff does not exist, please identify those circumstances, explain the basis for your
presentation policy, and quantify the gross amount of the financial assets and financial
liabilities that are offset in the balance sheet. For example, please tell us whether you
have offset securities owned (long positions) with securities sold, but not yet purchased
(short positions), along with any basis for your presentation policy and the related gross
amounts that are offset.

Management Response:

The Company has not offset financial assets and financial liabilities in its consolidated balance
sheets where a right of setoff does not exist.

Finally, if you accounted for repurchase agreements, securities lending transactions, or other
transactions involving the transfer of financial assets with an obligation to repurchase the
transferred assets as sales and did not provide disclosure of those transactions in your
Management’s Discussion and Analysis, please advise us of the basis for your conclusion that
disclosure was not necessary and describe the process you undertook to reach that conclusion. We
refer you to paragraphs (a)(1) and (a)(4) of Item 303 of Regulation S-K.

Management Response:

There were no repurchase agreements, securities lending transactions, or other transactions
involving the transfer of financial assets with an obligation to repurchase the transferred assets
accounted for as sales.

5

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 212-578-2005. For your convenience, we are
sending a copy of this letter to you via e-mail, in addition to filing it on EDGAR under the form
type label CORRESP.

Sincerely,

/s/ Peter M. Carlson

Peter M. Carlson

6