William O’Donnell
Executive Vice President and
Chief Accounting Officer
bodonnell1@metlife.com
December 19, 2017
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-Q for the Quarterly Period Ended September 30, 2017
Filed November 6, 2017
File No. 001-15787
Dear Ladies and Gentlemen:
This letter sets forth the response of MetLife, Inc. (the “Company”) to the comments contained in your letter dated December 5, 2017 regarding the Company’s Form 10-Q 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.
Form 10-Q for the Quarterly Period Ended September 30, 2017
Management’s Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP and Other Financial Disclosures, page 183
| 1. | “Operating revenues”, “operating expenses” and “operating earnings” that you identify as non-GAAP measures appear to be titles that are the same as, or confusingly similar to, those used for GAAP financial measures and precluded by Item 10(e)(ii)(E) of Regulation S-K. As such, please confirm to us that you will revise the titles of these measures in future filings to provide an appropriate description of each measure that complies with Item 10(e). |
Management’s Response:
We confirm that, to the extent we include such non-GAAP measures in our filings beginning with 2017 fourth quarter and full-year disclosures, we will revise the titles of those measures to provide an appropriate description of each measure that complies with Item 10(e).
Office of Healthcare & Insurance
Securities and Exchange Commission
December 19, 2017
Page 2
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 212-578-5353. For your convenience, we are filing this letter on EDGAR under the form type label CORRESP.
| Sincerely, |
| /s/ William O’Donnell |
| William O’Donnell |
| cc: | Steven A. Kandarian |
John C. R. Hele
Stephen W. Gauster
