February 16, 2011

Reinsurance Group of America, Incorporated
1370 Timberlake Manor Parkway
Chesterfield, Missouri 63017

Ladies and Gentlemen:

     We have acted as counsel to Reinsurance Group of America, Incorporated, a Missouri corporation (the “Company”), in connection with the remarketing of preferred securities (the “Preferred Securities”) issued as part of the Company’s Trust PIERS Units issued on December 18, 2001 in a public offering, pursuant to the Prospectus Supplement dated February 16, 2011 (the “Prospectus Supplement”) to the Prospectus (the “Prospectus”) contained in the Company’s Registration Statement on Form S-3 (File Nos. 333-172296 and 333-172296-01) filed by the Company pursuant to the Securities Act of 1933, as amended. Except as otherwise indicated herein, all capitalized terms used in this letter have the same meaning assigned to them in the Prospectus Supplement.

     In rendering our opinion, we have examined and relied upon, without independent investigation as to matters of fact, the Prospectus Supplement and such other documents, certificates and instruments as we have considered relevant for purposes of this opinion. We have assumed without independent verification that the factual information set forth in the Prospectus Supplement is accurate and complete in all material respects and our opinion is conditioned expressly on, among other things, the accuracy as of the date hereof, and the continuing accuracy, of all of such factual information through and as of the date of issuance of the remarketed Preferred Securities. Any material changes in the facts referred to, set forth or assumed herein or in the Prospectus Supplement may affect the conclusions stated herein

     In rendering our opinion, we have considered the applicable provisions of (a) the Internal Revenue Code of 1986, as amended (the “Code”) as in effect on the date hereof, and our interpretations of the Code, (b) the applicable Treasury regulations as currently in effect and our interpretations of such regulations (the “Regulations”), (c) current administrative interpretations by the Internal Revenue Service (“Service”) of the Regulations and the Code, and (d) existing judicial decisions, all of which are subject to change or modification at any time (possibly with retroactive effect) and such other authorities as we have considered relevant. It should be noted that such laws, Code, Regulations, judicial decisions and