MetLife, Inc.

200 Park Ave

New York, NY 10166

Robin Wagner

Assistant General Counsel

Law Department

T: 212-578-9071

VIA EDGAR TRANSMISSION

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Attn: Sonny Oh, Esq.

Senior Counsel, Division of Investment Management –

Disclosure Review and Accounting Office

February 11, 2021

Re: Metropolitan Life Insurance Company

Metropolitan Life Separate Account UL

Post-Effective Amendment No. 28 to Registration Statement

File No. 33-91226

To the Commission:

On behalf of Metropolitan Life Separate Account UL (the “Separate Account”) of Metropolitan Life Insurance Company (the “Company), transmitted herewith for filing is the Separate Account’s Post-Effective Amendment No. 28 (the “Amendment”) to its Registration Statement on Form N-6 (“Registration Statement) with respect to interests in the Separate Account offered under Variable Universal Life Policies issued through the Separate Account (the “Contracts”).

The current filing is being made under Rule 485(a) of the Securities Act of 1933 (“Securities Act”) to include updates that have been made to comply with the new Form N-6 requirements such as Items 2, 3, 5 and 11 of the form. Other routine updates and non-material changes have also been made.

To the extent applicable, this filing reflects Staff comments that were provided in connection with Post-Effective amendment filings made under Rule 485(a) with respect to Metropolitan Tower Life Insurance Company Separate Account Two (File No. 2-95019) and Metropolitan Life Insurance Company Separate Account UL (File No. 33-32813) each filed with the Commission on November 20, 2020. The Company looks forward to receiving the Staff’s comments on the Amendment. The Company intends to file additional post-effective amendments and delaying amendments for the Registration Statement with the ultimate goal of going effective on or about May 1, 2021.

If you have any questions or comments regarding the Amendment, please call Tom Conner of Vedder Price at (202) 312-3331.

Sincerely,

METROPOLITAN LIFE INSURANCE COMPANY
By:	/s/ Robin Wagner
Name:	Robin Wagner
Title:	Assistant General Counsel