June 28, 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 May 11, 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 May 2, 2018 letter.

Notes to Consolidated Financial Statements

Note 16. Short Duration Contracts, page 148

1.    We acknowledge your response to our prior comment one. It appears that
you have a total
      of at least $4.2 billion of liability for unpaid claims and claims
adjustment expenses
      comprised of $2 billion related to short duration contracts (as shown on
page 150 in the
      the reconciliation of the net incurred and paid claims development tables
to the liability
      for claims and claim adjustment expense) and $2.2 billion related to long
duration
      contracts (as indicated in your response). We are unable to agree with
your conclusion
      based on information you have provided in your response that information
required by
      ASC 944-40-50-3 is not material. In this regard, information required by
ASC 944-40-50-
 Todd C. Larson
Reinsurance Group of America, Inc.
June 28, 2018
Page 2
         3 includes much more than the ending balance of the liability for
unpaid claims and claims
         adjustment expenses. As previously requested, please provide us the
information required
         by ASC 944-40-50-3 separately by short duration and long duration
contracts.
       You may contact Sasha Parikh at 202-551-3627 or Jim Rosenberg at
202-551-3679 with
any questions.

FirstName LastNameTodd C. Larson
Comapany NameReinsurance Group of America, Inc.
                                                             Division of
Corporation Finance
June 28, 2018 Page 2                                         Office of
Healthcare & Insurance
FirstName LastName