April 22, 2020

Todd Larson
Senior Executive Vice President & Chief Financial Officer
REINSURANCE GROUP OF AMERICA INC
16600 Swingley Ridge Road
Chesterfield, Missouri 63017

       Re: REINSURANCE GROUP OF AMERICA INC
           Form 10-K for the Fiscal Year Ended December 31, 2019
           Filed February 27, 2020
           File No. 001-11848

Dear Mr. Larson:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2019

Notes to consolidated financial statements
Note 2: Significant Accounting Policies
Future Policy Benefits, page 98

1.     Although you disclose your policy for short-duration premium deficiency
assessments in
       the third paragraph of this policy note, you do not appear to disclose
your policies for:
         Short-duration premium recognition;
         Short-duration claims reserving; and/or
         The amortization of deferred policy acquisition costs for
short-duration contracts.
       Please provide us proposed revised disclosure for these policy
statements to be included in
       future periodic reports. Otherwise tell us where you disclose these
policies or why their
       disclosure is not warranted.
Note 16: Policy Claims and Benefits
Rollforward of Claims and Claim Adjustment Expenses, page 146
 Todd Larson
REINSURANCE GROUP OF AMERICA INC
April 22, 2020
Page 2

2.       You disclose unfavorable prior year development on incurred claims of
$154 million in
         2019. Given that this amount is significant to your pre-tax income of
$1,132 million in
         2019, please tell us how your disclosure provides useful information
to financial statement
         users to facilitate their analysis of the amount, timing, and
uncertainty of cash flows
         arising from insurance contracts and the development of the liability
for unpaid claims
         consistent with the objective outlined in paragraph BC 2 of ASU
2015-09. In your
         response tell us:
           How your disclosure complies with the guidance in ASC 944-40-50-3.
In this regard,
              your disclosure appears to merely identify prior year development
but fails to explain
              the underlying reasons for this development.
           The components of your $154 million unfavorable development over and
above the
              apparent $28 million in aggregate unfavorable development ($5
million favorable in
              your U.S. and Latin America short-duration contracts offset by
$33
              million unfavorable in your Asia Pacific short-duration
contracts) depicted in
              your claims development tables on pages 144 and 145. At a
minimum, provide the
              following components for the apparent $126 million in incremental
unfavorable
              development:
                o  The amount of prior year development for accident years
prior to 2012 for each
                   of the claims development tables referred to above;
                o  The short-duration lines of business not included in the
claims development
                   tables and the prior year development for those lines in
2019 for each line; and
                o  The amount of prior year development related to your
long-duration claims;
           Why you do not include the short-duration lines of business
identified in the
              preceding bullet in your tables;
           Whether the prior year development on your long-duration claims is
offset by an
              opposite impact on your liability for future policy benefits; and
           Your consideration for disclosing the information in the preceding
bullets.

       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Dave Irving at 202-551-3321 or Mark Brunhofer at
202-551-3638 with
any questions.



FirstName LastNameTodd Larson             Sincerely,
Comapany NameREINSURANCE GROUP OF AMERICA INC
                                          Division of Corporation Finance
April 22, 2020 Page 2                     Office of Finance
FirstName LastName