September 21, 2018

Todd C. Larson
Senior Executive Vice President and Chief Financial Officer
Reinsurance Group of America, Inc.
16600 Swingley Ridge Road
Chesterfield, MO 63017

       Re: Reinsurance Group of America, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed February 27, 2018
           File No. 001-11848

Dear Mr. Larson:

        We have reviewed your September 4, 2018 response to our comment letter
and have the
following comment. In our comment, we may ask you to provide us with
information so we may
better understand your disclosure.

       Please respond to the comment within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comment applies to your facts and circumstances, please tell us why in your
response.

      After reviewing your response to the comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in
our August 24, 2018 letter.

Form 10-K for the fiscal year ended December 31, 2017

Notes to Consolidated Financial Statements
Note 16. Short Duration Contracts, page 148

1.    Please refer to your September 4, 2018 response and address the
following:
        Explain to us why you have to use the "approach" described in your
response to our
         second bullet of our prior comment in order to estimate the break-out
of claims
         incurred between the current and prior years for the segments not
included in the 10
         year tables. Also explain to us why you believe your "approach"
results in a reasonable
         estimate of this break-out.
        As previously requested, please provide us a reconciliation of the long
and short-
 Todd C. Larson
Reinsurance Group of America, Inc.
September 21, 2018
Page 2
             duration claims incurred balance per the three year roll forward
tables to the claims
             and other policy benefits line item on the income statement for
each of the years
             presented. Explain how each reconciling item is derived and/or
where it comes from in
             your accounting records.

       You may contact Sasha Parikh at 202-551-3627 or Jim Rosenberg at
202-551-3679 with
any questions.



FirstName LastNameTodd C. Larson                             Sincerely,
Comapany NameReinsurance Group of America, Inc.
                                                             Division of
Corporation Finance
September 21, 2018 Page 2                                    Office of
Healthcare & Insurance
FirstName LastName