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1095 Avenue of the Americas

New York, NY 10036

Peter M. Carlson

Executive Vice President and

Chief Accounting Officer

pcarlson@metlife.com

June 13, 2011

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, 2010

Filed February 25, 2011

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 May 27, 2011, regarding the Company’s Annual Report on Form 10-K for the year
ended December 31, 2010 (“2010 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’s Discussion and Analysis

Industry Trends

Mortgage and Foreclosure-Related Exposures, page 77

    1.

    You disclose on page 77 that other than repurchase obligations which are subject to
indemnification by sellers of acquired assets...(your) exposure to repurchase obligations and
losses related to origination deficiencies is limited to the approximately $52 billion of
loans originated by MetLife Bank (all of which have been originated since August 2008) and to
servicing deficiencies after the date of acquisition, and management is satisfied that
adequate provision has been made in the Company’s consolidated financial statements for all
probable and reasonably estimable repurchase obligations and losses. Please disclose the
following within your Notes:

    •

    The amount of your accrual for loan repurchases as of December 31, 2010, and the impact
of loan repurchases on your results of operations for each period presented;

    •

    The amount of loans you repurchased in each period presented;

    •

    The amount of loans for which the acquirers of your originated loans are seeking to be
reimbursed by you; and

    •

    Your methodology for estimating the accrual for loan repurchases.

Management Response:

Repurchase obligations related to residential mortgage loans result from honoring origination
representations and warranties made at the time of sale. These representations and warranties can
also be honored by indemnifying the purchaser and compensating them for losses through a
“make-whole” payment. The Company establishes reserves at the time of sale for total anticipated
life-of-loan losses due to repurchases and indemnifications. These reserves are re-evaluated each
quarter for adequacy. The reserves are released when repurchase demands or indemnifications are
honored (“charge-offs”), or when loans prepay and the exposures are eliminated.

Significant drivers of repurchase exposure include the volume of loan sales and prepayments,
product guidelines, underwriting quality, and the investors’ quality control or compliance process.
Internal models are used to estimate losses for groups of loans with similar risk characteristics
(“pools”), typically based on investor, product type, and origination channel. The model is a
vintage analysis that tracks historical information within these pools by year of origination /
sale, including such information as self-reported violations, borrower misrepresentations, volume
of repurchase demands, and the timing and amount of actual losses. This information is used to
project  future losses on outstanding loan balances subject to representations and warranties.
The reserves that are estimated using the historical loss experience are further adjusted for any
changes deemed appropriate due to deterioration or improvement in the credit quality of the
outstanding loans, significant changes in underwriting standards or in investor contractual terms,
and changes in the general economic environment which suggest

-2-

higher or lower incidence of prepayments, defaults, fraud, or aggressive investor demands.

The Company began originating and selling mortgages in 2008 and had reserves of $56 million, $34
million and $2 million at December 31, 2010, 2009 and 2008, respectively. Most of the growth in our
reserves is due to new loan sales. The Company incurred charge-offs of $10 million, $6 million and
$0 for the years ended December 31, 2010, 2009, and 2008, respectively. The Company repurchased or
provided make-whole payments on loans with principal amounts of $28 million, $26 million and $0 for
the years ended December 31, 2010, 2009 and 2008, respectively. At December 31, 2010, there were
$20 million in loans for which the acquirers of the Company’s originated loans are seeking to be
reimbursed. Management expects that a significant portion of these claims will be successfully
defended.

Based on the immateriality of the Company’s exposures, we do not believe that significant expansion
of our disclosure would be helpful to the reader. However, in order to provide useful information
to the reader regarding the magnitude of the Company’s exposures, commencing with the Company’s
Form 10-Q filing for the quarter ending June 30, 2011, we will add the following disclosure to Item
2. Management’s Discussion and Analysis of Financial Condition and Results of Operations —
Industry Trends — Mortgage and Foreclosure-Related Exposures:

    Reserves for representation and warranty repurchases and indemnifications were $[ ] million and
$56 million at June 30, 2011 and December 31, 2010, respectively.

-3-

Composition of Investment Portfolio and Investment Portfolio Results

Fixed Maturity and Equity Securities, Available for Sale

Fixed Maturity Securities Credit Quality — Ratings, page 132

    2.

    On page 133 you present a table of fixed maturity securities, based on estimated fair
value, by sector classification and by NRSRO designation and the equivalent designations of
the NAIC. Please tell us whether you perform an analysis, including considering current
market credit spreads, for your investments, to determine either that the ratings assigned by
the third party credit rating agencies are reasonable or to otherwise determine the credit
quality of your investments. If so, please summarize for us the procedures you perform.
Also, tell us the investments for which you performed these procedures and, for those where
these procedures resulted in you concluding that the rating assigned by the third party credit
rating agency at December 31, 2010 was significantly different, provide the fair value and
amortized cost of those investments, as well as how and why your conclusion differed.

Management Response:

The Company internally rates fixed maturity securities within certain asset sectors for the purpose
of making investment recommendations (i.e., buy, sell and hold actions). The Company does not use
its internal ratings to adjust ratings obtained from NRSRO and NAIC that are used in the
Company’s Form 10-K disclosures, such as those on page 133 of the 2010 Form 10-K.

The Company independently analyzes fixed maturity securities in which it invests and, for certain
asset sectors, assigns an internal rating. The Company has internal research teams which are
specialized by asset sectors (e.g., public corporate, private corporate and structured securities)
and those teams perform  independent fundamental analyses on  issuers in their particular
sectors. NAIC ratings and NRSRO research, ratings and rationale are just a few of the inputs in the
Company’s process to develop its internal ratings.

The procedure for analyzing fixed maturity securities generally includes an evaluation of both
quantitative and qualitative factors, including:

    •

    Evaluating offering documents and other materials describing the securities;

    •

    Performing an independent forecast of  cash flows required to repay the
obligations represented by these securities;

    •

    Conducting a sensitivity analysis to determine  resilience of such securities
in adverse environments;

    •

    Assessing qualitative factors related to  securities such as country risk,
industry factors and competitive position; and

    •

    Determining whether  loss adjusted returns expected from the securities are
appropriate.

-4-

In addition, the Company monitors and, if necessary, revises internal ratings in light of changes
in the issuer’s performance, industry dynamics and economic events, among other factors.

The Company has a long practice of internally rating the following fixed maturity securities
sectors: corporate securities, foreign government, RMBS, CMBS and ABS; and a more recent process to
internally rate state and political subdivision securities. Only a portion of the state and
political subdivision securities portfolio had been internally rated as of December 31, 2010. The
Company does not internally rate U.S. Treasury and agency securities. While structured securities
(RMBS, CMBS and ABS) are internally rated, the Company’s internal scale consists of five gradients
and does not correspond to the NRSRO rating scale of eight letter gradients. While appropriate
risk management review had been completed prior to the Company’s acquisition of American Life
Insurance Company on November 1, 2010 and updated as necessary through year end 2010, only a
portion of the international fixed maturity security portfolio was internally rated as of December 31,
2010.

The Company does not have a formal process to compare its internal ratings to the NRSRO ratings.
However, we consider a 3 notch, or more, difference between our internal rating and the NRSRO
rating to be a significant difference. In this context, a 3 notch difference is, for example, the
difference between A1 and Baa1, using the Moody’s Investor Service rating scale. For the domestic
fixed maturity security portfolio for which a comparable scale internal rating was available (U.S.
corporate securities, foreign corporate securities and foreign government securities) the amortized
cost and estimated fair value of the fixed maturity securities with a 3 notch, or more, difference
between the Company’s internal rating and the NRSRO rating as of December 31, 2010, are as follows:

    Amortized

    Estimated

    Cost

    Fair Value

    (In Millions)

    Internal rating 3 or more notches above NRSRO rating

    $
    5,361

    $
    4,932

    As % of portfolio with a comparable internal scale

    4.9
    %

    4.3
    %

    Internal rating 3 or more notches below NRSRO rating

    $
    1,640

    $
    1,751

    As % of portfolio with a comparable internal scale

    1.5
    %

    1.5
    %

In general, the Company’s internal ratings can be different from NRSRO ratings, as the Company’s
process reflects its own judgment of the credit risk. In addition, the aforementioned ongoing
monitoring process can result in faster changes to our internal
ratings than we have observed in changes to NRSRO ratings for individual issuers and securities.

-5-

Investments

Composition of Investment Portfolio and Investment Portfolio Results

Mortgage Loans

Mortgage Loan Credit Quality — Restructured, Potentially Delinquent, Delinquent or Under Foreclosure, page 143

    3.

    For your loan modification activity, please revise your disclosure to address the
following:

    •

    The types and amount of loans for which you modified the original terms of the
contract;

    •

    Quantify the default and/or success rates of these loan modifications; and

    •

    Clarify whether these modified loans are in your performing portfolio.

Management’s Response:

The table on page 144 presents, for each of the mortgage loan portfolio segments, the following
four loan classifications: performing, restructured, potentially delinquent and delinquent or under
foreclosure. As noted on page 144, the Company defines restructured mortgage loans as loans in
which the Company, for economic or legal reasons related to the debtor’s financial difficulties,
grants a concession to the debtor that it would not otherwise consider. The “restructured” line
item in the table includes the performing modified loans, which are substantially all of the
modified loans, whereas non performing modified loans are included either in the “potentially
delinquent” or “delinquent or under foreclosure” line items.

Commencing with the Company’s Form 10-Q filing for the quarter ending June 30, 2011, we will add
the following footnotes (a), (b) and (c) (highlighted in bold) to the table in Item 2. Management’s
Discussion and Analysis of Financial Condition and Results of Operations- Investments-Composition
of Investment Portfolio and Investment Portfolio Results-Mortgage Loans-Mortgage Loan Credit
Quality — Restructured, Potentially Delinquent, Delinquent or Under Foreclosure:

-6-

The following table presents the recorded investment and valuation allowance for all mortgage loans
held-for-investment distributed by the above stated loan classifications at:

    December 31,

    2010

    2009

    % of

    % of

    Recorded

    % of

    Valuation

    Recorded

    Recorded

    % of

    Valuation

    Recorded

    Investment

    Total

    Allowance

    Investment

    Investment

    Total

    Allowance

    Investment

    (In millions)

Commercial:

    Performing

    $
    37,489

    99.1
    %

    $
    528

    1.4
    %

    $
    35,066

    99.7
    %

    $
    548

    1.6
    %

    Restructured (a)

    93

    0.2

    6

    6.5
    %

    —

    —

    —

    —
    %

    Potentially delinquent

    180

    0.5

    28

    15.6
    %

    102

    0.3

    41

    40.2
    %

    Delinquent or under foreclosure

    58

    0.2

    —

    —
    %

    8

    —

    —

    —
    %

    Total

    $
    37,820

    100.0
    %

    $
    562

    1.5
    %

    $
    35,176

    100.0
    %

    $
    589

    1.7
    %

Agricultural (1):

    Performing

    $
    12,486

    97.9
    %

    $
    35

    0.3
    %

    $
    11,950

    97.5
    %

    $
    33

    0.3
    %

Restructured (b)

    33

    0.3

    8

    24.2
    %

    36

    0.3

    10

    27.8
    %

    Potentially delinquent

    62

    0.5

    11

    17.7
    %

    128

    1.0

    34

    26.6
    %

    Delinquent or under foreclosure (b)

    170

    1.3

    34

    20.0
    %

    141

    1.2

    38

    27.0
    %

    Total

    $
    12,751

    100.0
    %

    $
    88

    0.7
    %

    $
    12,255

    100.0
    %

    $
    115

    0.9
    %

Residential (2):

    Performing

    $
    2,221

    96.2
    %

    $
    12

    0.5
    %

    $
    1,389

    94.4
    %

    $
    16

    1.2
    %

    Restructured (c)

    4

    0.2

    —

    —
    %

    1

    0.1

    —

    —
    %

    Potentially delinquent

    4

    0.2

    —

    —
    %

    10

    0.7

    —

    —
    %

    Delinquent or under foreclosure (c)

    79

    3.4

    2

    2.5
    %

    71

    4.8

    1

    1.4
    %

    Total

    $
    2,308

    100.0
    %

    $
    14

    0.6
    %

    $
    1,471

    100.0
    %

    $
    17

    1.2
    %

    (1)

    Of the $12.8 billion of agricultural mortgage loans outstanding
at December 31, 2010, 53% were subject to rate resets prior to
maturity. A substantial portion of these mortgage loans have been
successfully renegotiated and remain outstanding to maturity.

    (2)

    Residential mortgage loans held-for-investment consist primarily
of first lien residential mortgage loans, and to a much lesser
extent, second lien residential mortgage loans and home equity
lines of credit.

    (a)

    As of December 31, 2010, restructured commercial mortgage loans were comprised of
five restructured loans, all of which were performing.

    (b)

    As of December 31, 2010, restructured agricultural mortgage loans were comprised of five
restructured loans, all of which were performing. Additionally, as of December