[LOGO OF K&L GATES]               Kirkpatrick & Lockhart Preston Gates Ellis LLP
                                  1601 K Street NW
                                  Washington, DC 20006-1600

                                  T 202.778.9000   www.klgates.com

                                             Diane E. Ambler
                                             202.778.9886
                                             Fax: 202.778.9100
                                             diane.ambler@klgates.com

February 4, 2015

EDGAR FILING

United States Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re:  MetLife Insurance Company USA
     Form S-3 Registration Statement
     File No. 333-____________

Dear Sir or Madam:

On behalf of MetLife Insurance Company USA ("MetLife"), transmitted herewith for
filing, pursuant to the requirements of Section 10(a) of the Securities Act of
1933, as amended (the "1933 Act") and Rule 101(a) of Regulation S-T, is a
conformed electronic format copy of a registration statement on Form S-3 (the
"Registration Statement") with respect to the Registered Fixed Account Option
("RFAO"), which has a market value adjustment feature and which is available in
conjunction with certain group variable annuity contracts issued by MetLife. The
Registration Statement has been filed in accordance with Rule 413 under the 1933
Act to register additional securities in the same class as already in effect for
RFAO pursuant to a registration statement filed on Form S-3 (SEC File No.
333-178886).

The existing disclosure has been updated as necessary and has otherwise not
materially changed. The Registration Statement includes a delaying amendment in
accordance with Rule 473 under the 1933 Act. MetLife requests that the
Securities and Exchange Commission declare the Registration Statement effective
May 1, 2015 or as soon thereafter as practicable. MetLife intends to file a
pre-effective amendment in early April to (i) provide the requisite financial
statements and consents and (ii) address any comments raised by the Commission
staff.

This transmission contains conformed signature pages, the manually signed
originals of which are maintained at MetLife's offices. Please contact Andras P.
Teleki at (202) 778-9477 or the undersigned at (202) 778-9886 with any questions
comments.

                                           Sincerely,

                                           /s/ Diane E. Ambler
                                           ---------------------------------
                                           Diane E. Ambler

Enclosure

cc   Sonny Oh, SEC