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1095 Avenue of the Americas

New York, NY 10036

Peter M. Carlson

Executive Vice President &

Chief Accounting Officer

May 14, 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

Filed February 26, 2010

File Number: 001-15787

Dear Mr. Rosenberg:

This letter sets forth the response of MetLife, Inc. (the “Company”) to the comments contained in
your letter dated April 30, 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.

Item 7 – Management Analysis of Financial Position and Results of Operations

Summary of Critical Accounting Estimates

Embedded Derivatives, page 73

    1.

    Please revise your disclosure to include quantified and narrative disclosure of the impact
that reasonably likely changes in the company’s own credit risk used to estimate fair value
would have on the financial statements.

Management Response:

Commencing with the Company’s Form 10-K filing for the year ended December 31, 2010, the following
disclosure will be added to Item 7 — Management’s Discussion and Analysis of Financial Condition
and Results of Operations — Summary of Critical Accounting Estimates — Embedded Derivatives:

Mr. James B. Rosenberg

May 14, 2010

Page 2

As described above, the valuation of variable annuity guarantees accounted for as
embedded derivatives includes an adjustment for the Company’s own credit, which is
subject to variability. The table below illustrates the impact that a range of
reasonably likely variances in credit spreads would have on the Company’s
consolidated balance sheet, excluding the effect of income tax. Changes in the
carrying values of policyholder account balances (“PABs”) would be reported in net
investment gains (losses) and changes in the carrying value of deferred acquisition
costs (“DAC”) and value of business acquired (“VOBA”) would be reported in other
expenses. However, these estimated effects do not take into account potential
changes in other variables, such as equity price levels and market volatility, that
can also contribute significantly to changes in carrying values. Therefore, the
table does not necessarily reflect the ultimate impact on the Consolidated Financial
Statements under the credit spread variance scenarios presented below.

In determining the ranges presented, the Company has considered current market
conditions as well as the market level of spreads that can reasonably be anticipated
over the near term. The ranges presented do not reflect extreme market conditions
experienced during the 2008 and 2009 economic crisis as the Company does not
consider those to be reasonably likely events in the near future.

    Carrying Value

    At December 31, 2010

    PABs

    DAC and VOBA

    (In millions)

    XXX bps increase in the Company’s credit
spread

    $XXX

    $XXX

    As reported

    XXX

    XXX

    XXX bps decrease in the Company’s credit
spread

    XXX

    XXX

Mr. James B. Rosenberg

May 14, 2010

Page 3

Consolidated Results of Operations

Year Ended December 31, 2009 compared with the Year Ended December 31, 2008,

Page 80

    2.

    Please revise your disclosure to reconcile the amount disclosed for the unfavorable variance
in net investment gains (losses) of $5.2 billion to amount disclosed on the income statement.
Please disclose the amounts attributable to each factor included to explain the negative
change in freestanding derivatives on page 82. Finally, please disclose the amount of the
losses attributable to a narrowing of the company’s own credit spread.

Management Response:

The $5.2 billion unfavorable variance presented on page 82 of the Company’s 2009 Form 10-K
highlights the impact the change in net investment gains (losses), together with related offsets
and taxes, had on the year over year $5.8 billion change in income (loss) from continuing
operations, net of income tax. The following is a reconciliation of the amounts disclosed on the
Consolidated Statements of Operations to the $5.2 billion variance (in billions):

    Net investment gains (losses) per Consolidated Statements of
Operations:

    Year Ended December 31, 2009

    $
    (7.8
    )

    Year Ended December 31, 2008

    1.8

    Variance

    (9.6
    )

    Other variances — related offsets (principally amortization of DAC
and VOBA)*

    1.5

    Pre-tax variances

    (8.1
    )

    Income tax effect

    2.9

    Variance in net investment gains (losses), net of related
adjustments and income tax

    $
    5.2

    *

    Related offsets to net investment gains (losses) are presented in the
“Reconciliation of GAAP revenues to operating revenues and GAAP expenses to operating
expenses” on page 84 of the 2009 Form 10-K — $(27) million less $(700) million less $18
million plus $839 million.

Commencing with the Company’s Form 10-Q filing for the quarter ended June 30, 2010, we will include
the detailed disclosures requested as relevant to the periods reported in the respective filings.
The following is an example of the proposed disclosure based on the year ended December 31, 2009
compared with the year ended December 31, 2008:

During the year ended December 31, 2009, MetLife’s income (loss) from continuing
operations, net of income tax, decreased $5.8 billion to a loss of $2.3 billion from
income of $3.5 billion in 2008. The year over year change was predominantly due to a
$9.6 billion unfavorable variance in net investment gains (losses) — losses of
$7.8 billion in 2009 from gains of $1.8 billion in 2008. Offsetting this variance
were changes in adjustments related to net investment gains (losses) of $1.5
billion, principally associated with DAC and VOBA

Mr. James B. Rosenberg

May 14, 2010

Page 4

amortization, and $2.9 billion of income tax resulting in a total unfavorable
variance related to net investment gains (losses) of $5.2 billion.

The unfavorable variance in net investment gains (losses), net of related
adjustments and income tax, was primarily driven by losses on freestanding
derivatives, partially offset by gains on embedded derivatives associated with
variable annuity minimum benefit guarantees, and decreased losses on fixed maturity
securities. The negative change in freestanding derivatives, from gains in the prior
year to losses in the current year, totaled $8.6 billion, of which $8.1 billion was
primarily attributable to the following factors: the effect of rising interest
rates on certain interest rate-sensitive derivatives that are economic hedges of
certain invested assets and insurance liabilities totaling $3.3 billion; equity
market and interest rate derivatives that are economic hedges of embedded
derivatives totaling $3.1 billion and $1.2 billion, respectively; and weakening
U.S. Dollar on certain foreign currency sensitive derivatives totaling $0.5 billion.
Losses on embedded derivatives decreased from losses to gains and were driven
primarily by rising interest rates and improving equity market performance. The
gains were net of losses of $3.2 billion attributable to a narrowing of the
Company’s own credit spread. Losses on the freestanding derivatives hedging these
embedded derivatives risks substantially offset the change in the liabilities
attributable to market factors, excluding the adjustment for the change in the
Company’s own credit spread, which is not hedged. The decrease in losses on fixed
maturity securities is primarily attributable to lower net losses on sales of fixed
maturity securities, partially offset by increased impairments due to the current
financial market conditions, although this trend lessened in the latter part of
2009.

    3.

    Please include an explanation for the change in the provision for income tax expense
(benefit) in results of operations.

Management Response:

Commencing with the Company’s Form 10-K filing for the year ended December 31, 2010, we will
include an explanation for the change in the provision for income tax expense (benefit) in
Item 7 – Management’s Discussion and Analysis of Financial
Condition and Results of Operations – Consolidated Results of Operations.
 Further, in future interim filings we will include similar disclosure if a
significant fluctuation occurs. The following is an example of the proposed disclosure based on
the year ended December 31, 2009 compared with the year ended December 31, 2008:

The income tax benefit for the twelve months ended December 31, 2009 was $2,015
million, or 47% of the loss from continuing operations before benefit for income
tax, compared with income tax expense of $1,580 million, or 32% of income from
continuing operations before provision for income tax for 2008. The Company’s 2009
effective tax rate differs from the U.S. statutory rate of 35% primarily due to the
impact of certain permanent tax differences, including non-taxable investment income
and tax credits for investments in low income housing, in relation to the loss from continuing operations before income
tax, as well as certain foreign permanent tax differences. The

Mr. James B. Rosenberg

May 14, 2010

Page 5

Company’s 2008
effective tax rate differs from the U.S. statutory rate of 35% primarily due to the
impact of non-taxable investment income and tax credits for investments in low
income housing (see Note 15 “Income Tax” of the Notes to the Consolidated Financial
Statements for a reconciliation of the income tax provision at the U.S. statutory
rate to the provision for income tax as reported for continuing operations).

    4.

    In your discussion of other expenses you reference several factors that contributed to the
increase in expense. This discussion did not quantify the impact that each of these
significant factors had individually. Please revise your disclosure to quantify the changes
that resulted from each of the significant factors referenced. This also applies to other
disclosure in your document where multiple factors are referenced, but not quantified.

Management Response:

The following is an example of the proposed quantitative explanation of the factors influencing the
changes in other expenses based on the year ended December 31, 2009 compared with the year ended
December 31, 2008. Commencing with the Company’s Form 10-Q for the quarter ended June 30, 2010, we
will include similar disclosure in Item 7 – Management’s Discussion and Analysis of Financial
Condition and Results of Operations – Consolidated Results of Operations.

The key driver of the $444 million increase in other expenses stemmed from the
impact of market conditions on certain expenses, primarily from higher pension and
postretirement benefit costs of $213 million,
 primarily due to lower equity returns and interest rates, as well as higher reinsurance expenses
and letter of credit fees, which together increased $53 million. Also contributing
to the rise in other expenses was an increase of $102 million in variable costs such
as commissions and premium taxes as well as an increase of $63 million in other
employee related expenses such as corporate owned life insurance and deferred
compensation expense. These increases were partially offset by decreases totaling
$78 million related to professional services, travel, information technology and
advertising expenses, which reflect the impact of the Company’s Operational
Excellence initiative.

Commencing with the Company’s Form 10-Q filing for the quarter ended June 30, 2010, we will, as
appropriate, add quantitative information to other disclosures where multiple factors are
referenced.

Mr. James B. Rosenberg

May 14, 2010

Page 6

Notes to the Consolidated Financial Statements

Note 3. Investments

Mortgage Loans, page F-65

    5.

    Please disclose, preferably in a table, loans in your commercial loan portfolio grouped by
current loan-to-value ratio, as appropriate, to provide informative disclosure about different
levels of loan-to-value ratio along with the corresponding fair value. For example, groupings
could include loans classified as low, medium or high loan-to-value ratio with a note
explaining the definition of low, medium to high.

Management Response:

The Company currently discloses the average loan-to-value ratio of its commercial loan portfolio
within Item 7 — Management’s Discussion and Analysis of Financial Condition and Results of
Operations – Mortgage Loan Credit Quality – Monitoring Process – Commercial and Agricultural Loans
on pages 126-127 of the 2009 Form 10-K. Commencing with the Company’s Form 10-K filing for the
year ended December 31, 2010, we will add the following disclosure to Note 1 “Business, Basis of
Presentation and Summary of Significant Accounting Policies” of the Notes to the Consolidated
Financial Statements:

    In connection with monitoring the credit quality of its commercial loan portfolio,
the Company reviews, among other factors, the loan-to-value ratio of its commercial
loans. Loan-to-value ratio is a common measure in the assessment of the quality of
commercial mortgage loans. Loan-to-value ratio compares the amount of the loan to
the estimated fair value of the underlying collateral. A loan-to-value ratio greater
than 100% indicates that the loan amount is greater than the collateral value. A
loan-to-value ratio of less than 100% indicates an excess of collateral value over
the loan amount. The Company’s credit quality monitoring process includes a periodic
quality rating process and an evaluation of the estimated fair value of the
underlying collateral.

The following is an example of proposed additional disclosure based on the commercial mortgage loan
portfolio as of December 31, 2009. Commencing with the Company’s Form 10-K filing for the year
ended December 31, 2010, we will add similar disclosure to Note 3 “Investments – Mortgage Loans” of
the Notes to the Consolidated Financial Statements.

Mr. James B. Rosenberg

May 14, 2010

Page 7

    The carrying values, net of valuation allowances, and estimated fair values of the
commercial mortgage loan portfolio by the indicated loan-to-value ratio categories
were as follows at:

    December 31, 2009

    Carrying

    Value, Net

    of Valuation

    % of

    Estimated

    % of

    Loan-to-value ratio:

    Allowances

    Total

    Fair Value

    Total

    0%-50%

    $
    6,783

    20
    %

    $
    6,889

    21
    %

    51%-60%

    4,019

    12
    %

    3,963

    12
    %

    61%-70%

    8,699

    25
    %

    8,364

    26
    %

    71%-80%

    8,195

    24
    %

    7,658

    23
    %

    81%-90%

    4,996

    14
    %

    4,233

    13
    %

    91%-100%

    1,077

    3
    %

    868

    3
    %

    Greater than 100%

    818

    2
    %

    672

    2
    %

    Total commercial mortgage loans

    $
    34,587

    100
    %

    $
    32,647

    100
    %

*****

We acknowledge that:

    •

    the Company is responsible for the adequacy and accuracy of the disclosure in the
filing;

    •

    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; and

    •

    the Company may not assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

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