August 24, 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 August 8, 2018 response 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.

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 August 8, 2018 response and address the following:
        Explain to us why there does not appear to be any significant
reconciling items
         between the 2017 prior years incurred amount of $2,829,000 shown in
the short
         duration three year roll forward table of your response and the amount
of development
         in 2017 inherent in "US and Latin America" and "Asia Pacific" 10 year
tables in Note
         16. We note in this regard that you also have reserves for other short
duration contracts
         for which 10 year tables are not included.
        Explain to us why the incurred current year amount for 2017, 2016 and
2015 shown in
         the short duration three year forward table of your response increased
by $63 million,
 Todd C. Larson
Reinsurance Group of America, Inc.
August 24, 2018
Page 2
             $129 million and $172 million, respectively, with an equal
decrease in the incurred
             prior years amount as compared to the respective amounts in your
July 13, 2018
             response.
             Reconcile for us the sum of total incurred for 2017, 2016 and 2015
for both your long
             and short duration three year roll forward tables to each amount
for the respective year
             for the line item "claims and other policy benefits" on the
consolidated statements of
             income.
       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
August 24, 2018 Page 2                                         Office of
Healthcare & Insurance
FirstName LastName