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CORRESP

 William C. O’Donnell

Executive Vice President and

 Chief
Accounting Officer

 July 10, 2018

 VIA EDGAR

Office of Healthcare & Insurance

 Division of
Corporation Finance

 United States Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

       Re:

 MetLife, Inc.

 Form 10-K for the Year Ended December 31, 2017

Filed March 1, 2018

 File No. 001-15787

 Ladies and Gentlemen:

This letter sets forth the response of MetLife, Inc. (including its subsidiaries appropriate to the context, the “Company” or
“MetLife”) to the comments contained in your letter dated June 11, 2018 regarding the Company’s Form 10-K referenced above.

In response to your comments, we have reproduced your comments below in boldface, italic type and set forth our response immediately below
each comment. All references to dollar amounts in this response are on a pre-tax basis, unless otherwise noted.

Notes to the Consolidated Financial Statements

1. Business, Basis of Presentation and Summary of Significant Accounting Policies and Revisions, page 209

1. Please refer to your response to the first bullet of comment one. With respect to the group annuity reserves revision, tell us why
the $30 million reserve re-establishment in 2017 discussed in footnote (2) in your response was not considered a correction of an error in the 2017 quarterly periods.

Management’s Response:

 The
$301 million group annuity reserve re-establishment corrected immaterial errors of $9 million, $9 million and $13 million for the first
quarter, second quarter and third quarter of 2017, respectively. The $30 million adjustment did not correct an error for the 12-month period ended December 31, 2017 because it was timely applied when
that 12-month period was first reported.

 The Company revised previously reported amounts related
to the immaterially misstated group annuity reserves and assumed variable annuity guarantee reserves, as well as adjustments for other unrelated immaterial errors. (See Note 1 of the Notes to the Consolidated Financial Statements in MetLife,
Inc.’s Annual Report on Form 10-K for the year ended December 31, 2017 (the “2017 Annual Report”).) The Company also revised quarterly amounts in Note 21, Quarterly Results of Operations
(Unaudited) in the 2017 Annual Report for each of the quarterly periods in fiscal years 2017 and 2016. The revisions pertaining to the three months ended March 31, 2017 appear in a table in Note 1 of the Notes to the Interim Condensed
Consolidated Financial Statements (Unaudited) included in MetLife, Inc.’s Form 10-Q for the quarterly period ended March 31, 2018. The Company will continue to present a summary of the revisions to
prior period net income (loss) available to MetLife, Inc.’s common shareholders for the 2017 quarters in a table within each remaining Form 10-Q to be filed in 2018.

Please refer to our response below (Comment #4) for the materiality analysis for the group annuity and variable annuity revisions under the
rollover and iron curtain method for each interim and annual period.

1
 Sum of the quarterly amounts not equal to $30 million
due to rounding.

 Office of Healthcare & Insurance

Securities and Exchange Commission

 July 10, 2018

 Page
 2

 2. Refer to your response to the first bullet of comment one. With respect to the
assumed variable annuity guarantee reserves revision, you state that the $214 million impact of the change in fair value subsequent to December 31, 2016 did not correct an error as it was appropriately reported in 2017.

•

 Tell us how much of the $214 million revision in 2017 related to each
quarterly period.

•

 As the $214 million revision was discovered subsequent to the quarterly
periods being reported, please tell us why you believe the additional reserve for each quarter did not correct a material error in the interim periods.

Management’s Response:

 The
$214 million assumed variable annuity guarantee revision in 2017 corrected immaterial errors of $14 million, $47 million and $67 million for the first quarter, second quarter and third quarter of 2017, respectively. The fourth
quarter 2017 amount was $86 million and did not correct an error because it was timely applied when the quarter was first reported. Similarly, the $214 million adjustment did not correct an error for the
12-month period ended December 31, 2017 because it was timely applied when that 12-month period was first reported.

As noted in our response to Comment #1 above, the Company revised previously reported amounts related to the immaterially misstated assumed
variable annuity guarantee reserves and group annuity reserves, as well as adjustments for other unrelated immaterial errors. (See Note 1 of the Notes to the Consolidated Financial Statements in the 2017 Annual Report). The Company also revised
quarterly amounts in Note 21, Quarterly Results of Operations (Unaudited) in the 2017 Annual Report for each of the quarterly periods in fiscal years 2017 and 2016. The revisions pertaining to the three months ended March 31, 2017 appear in a
table in Note 1 of the Notes to the Interim Condensed Consolidated Financial Statements (Unaudited) included in MetLife, Inc.’s Form 10-Q for the quarterly period ended March 31, 2018. The Company
will continue to present a summary of the revisions to prior period net income (loss) available to MetLife, Inc.’s common shareholders for the 2017 quarters in a table within each remaining Form 10-Q to
be filed in 2018.

 Please refer to our response below to Comment #4 for the materiality analysis for the group annuity and variable
annuity revisions under the rollover and iron curtain method for each interim and annual period.

 3. Please refer to your response
to the third bullet of comment one. Tell us how you considered whether or not the following qualitative factors, either individually or in aggregate with all qualitative factors, indicate that the revisions are material to any of the interim or
annual periods.

•

 The misstatements appear to have arisen from an item capable of precise measurement.

•

 The effect the misstatements had on analyst expectations.

•

 The misstatements appear to have arisen with respect to a critical accounting policy that plays a
significant role in your operations or profitability.

•

 The effect the misstatements had on management’s compensation.

•

 The effect management or the auditors expected the misstatements would have on the market
reaction.

 Management’s Response:

In determining whether all identified uncorrected misstatements were material for the 2017 and 2016 interim periods and the annual periods
ended December 31, 2016 and 2015, management of the Company considered the quantitative and qualitative factors set forth in Staff Accounting Bulletin (“SAB”) Topic 1.M., “Materiality.” Additionally, management considered
SAB Topic 1.N., “Considering the effects of prior year misstatements when quantifying misstatements in the current year financial statements,” which requires that uncorrected misstatements be evaluated under both the rollover method and
the iron curtain method.

 Office of Healthcare & Insurance

Securities and Exchange Commission

 July 10, 2018

 Page
 3

 The analysis applied the qualitative considerations identified in SAB Topic 1.M. as follows:

a.
 Did the misstatement arise from an item capable of precise measurement or did it arise from an estimate
and, if from an estimate, the degree of imprecision inherent in the estimate?

 The valuation of
liabilities for amounts payable under insurance contracts (“insurance reserves”) and embedded derivative liabilities are critical accounting estimates for the Company. As disclosed in “Management’s Discussion and Analysis of
Financial Condition and Results of Operations” in the 2017 Annual Report, there is a degree of imprecision inherent in the estimation of these reserves and liabilities, particularly as it relates to the underlying assumptions used in the
valuations as they are based in part on management judgment.

 However, the misstatements
identified were not related to elements subject to the estimation process. With respect to the group annuity misstatement, the Company prematurely released reserves due to inadequate processes and procedures for identifying unresponsive and missing
group annuitants and pension beneficiaries. With respect to the assumed variable annuity guarantees misstatement, the underlying policyholder data used in the valuation of the embedded derivative liabilities was incorrect.

b.
 Did the misstatement mask a change in earnings or other trends?

No. The identified misstatements did not mask a change in earning or other trends. The line item affected by the group annuity
reserves item in the statement of operations was policyholder benefits and claims, and the impact on the balances in this line item was insignificant for all prior periods. The line item impacted by the variable annuity guarantee reserves item was
net derivative gains (losses), which is excluded from adjusted earnings (the primary segment performance metric and an important metric used by analysts) and is subject to significant fluctuation from period to period due to changes in equity
markets, foreign exchange rates, and interest rate markets and, therefore, not subject to a trend analysis.

 The following
charts2 show that the identified misstatements do not mask a change in after-tax earnings or other trends on a quarterly or annual basis. As noted above, the adjusted earnings trend lines are not
significantly different because only the group annuity misstatement had an impact on adjusted earnings and that impact was not significant.

2
 See Appendix for supporting details.

 Office of Healthcare & Insurance

Securities and Exchange Commission

 July 10, 2018

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 Office of Healthcare & Insurance

Securities and Exchange Commission

 July 10, 2018

 Page
 5

c.
 Did the misstatement hide a failure to meet analysts’ consensus expectations for the Registrant?

 No. Management does not believe these misstatements hid any failure to meet analyst expectations in
prior periods impacted, as supported by the analysis below. Analysts commonly use adjusted earnings per share (adjusted EPS) to analyze the Company. The analysis below compares the amount by which adjusted earnings per share exceeded, or fell short,
of analysts’ expectations at the time of our quarterly earnings release to the overstatement of adjusted earnings per share attributable to these two misstatements:

 The above analysis illustrates that the correction of the misstatements did not hide a
failure to meet analysts’ consensus expectations.

d.
 Did the misstatement change a loss into income or vice versa?

No. There were no periods where the misstatements resulted in a change from a loss into income or vice versa, and the
misstatements did not change the direction of any financial statement line item.

e.
 Did the misstatement impact a segment or other portion of the Registrant’s business identified as
playing a significant role in the Registrant’s operations or profitability?

 The group annuity
reserves misstatement impacted the Company’s U.S. reportable segment. However, the magnitude of the identified misstatement was not significant to the insurance reserves held within that segment, did not change, mask, or distort the trend in
adjusted earnings for that segment, or hide a failure to meet analyst expectations of adjusted earnings for that segment.

The operations relating to the assumed variable annuity guarantees from the Company’s former operating joint venture in
Japan are included within the MetLife Holdings reportable segment. However, the nature of the variable annuity guarantees misstatement did not impact segment results in any period because, as disclosed in Note 2 of the Notes to the Consolidated
Financial Statements in the 2017 Annual Report, net derivative gains (losses) are excluded from the Company’s segment performance metric, adjusted earnings.

f.
 Did the misstatement affect the Registrant’s compliance with regulatory requirements?

 No. The Company’s regulatory requirements relate primarily to statutory requirements for its
insurance subsidiaries. The misstatements had no effect on compliance with insurance regulatory requirements. The misstatements had minimal adverse impacts on the affected MetLife insurance subsidiaries’ solvency metrics used by insurance
regulators to help assure adequately capitalized insurers.

 Office of Healthcare & Insurance

Securities and Exchange Commission

 July 10, 2018

 Page
 6

g.
 Did the misstatement affect the Registrant’s compliance with loan covenants or other contractual
requirements?

 No. None of the misstatements affected the Company’s compliance with corporate
debt covenants or other contractual requirements.

h.
 Did the misstatement have the effect of increasing management’s compensation (e.g., by satisfying
requirements for the award of bonus or other forms of incentive compensation)?

 While the
misstatement related to the group annuity reserves would have impacted the adjusted earnings used in the determination of the amount available for prior-year annual cash incentive compensation, it would not have significantly affected the adjusted
earnings the Company used to determine the amount available for annual cash incentive compensation in any prior period had it been identified at the time. In addition, individual annual cash incentive awards are discretionary and depend on many
factors, not solely on adjusted earnings. The misstatement related to the assumed variable annuity guarantee reserves would not have impacted the adjusted earnings used in the determination of the amount available for prior-year annual cash
incentive compensation. With respect to non-cash incentive compensation, the misstatements would have had an insignificant or no impact on the value of prior period awards.

i.
 Did the misstatement involve concealment of an unlawful transaction?

No. The misstatements were inadvertent and there is no indication that either of these items was a result of fraud, illegal
acts, violation of contracts, or conflicts of interest.

 Other factors from SAB Topic 1.M.

SAB Topic 1.M. also notes that “[w]hen…management or the independent auditor expects (based, for example, on a
pattern of market performance) that a known misstatement may result in a significant positive or negative market reaction, that expected reaction should be taken into account when considering whether a misstatement is material.” Management
expected potential market reaction to the disclosure of the misstatements. However, management did not anticipate a significant long-term market reaction to these two misstatements, after giving consideration to the following factors:

◾
 In January 2018, the Company pre-released earnings for the fourth
quarter of 2017 and estimated a range for the group annuitant reserve charge. However, at the same time, the Company announced that it was still in the process of conducting a global review of related processes and procedures, that it had a material
weakness in internal control over financial reporting, that the Securities and Exchange Commission had made inquiries to the Company, and that it would delay its planned earnings release. Management believes that these uncertainties largely caused
the subsequent short-term fluctuation in the Company’s common stock price;

◾
 The amounts by which the restated adjusted earnings per share exceeded, or fell short of, analysts’
expectations at the time of the Company’s prior earnings releases were insignificant (see discussion under 3.c. above);

◾
 The misstatements were the result of errors that were self-discovered and individually self-disclosed; and

◾
 The impact of the misstatements on the Company’s then current book value individually amounted to less
than 1.5% of the a