To the Contract Owners of
General American Separate Account Twenty-Eight
and General American Separate Account Twenty-Nine
and Board of Directors of
Metropolitan Tower Life Insurance Company

Opinion on the Financial Statements and Financial Highlights

We have audited the accompanying statements of assets and liabilities of General American Separate Account Twenty-Eight and General American Separate Account Twenty-Nine (the "Separate Accounts") of Metropolitan Tower Life Insurance Company (the "Company") comprising each of the individual Divisions listed in Note 2 as of December 31, 2023, the related statements of operations for the year then ended, the statements of changes in net assets for each of the two years in the period then ended, the financial highlights in Note 7 for each of the five years in the period then ended, and the related notes. In our opinion, the financial statements and financial highlights present fairly, in all material respects, the financial position of each of the Divisions constituting the Separate Accounts of the Company as of December 31, 2023, and the results of their operations for the year then ended, the changes in their net assets for each of the two years in the period then ended, and the financial highlights for each of the five years in the period then ended, in conformity with accounting principles generally accepted in the United States of America.

Basis for Opinion

These financial statements and financial highlights are the responsibility of the Separate Accounts' management. Our responsibility is to express an opinion on the Separate Accounts' financial statements and financial highlights based on our audits. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Separate Accounts in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB.

We conducted our audits in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statements and financial highlights are free of material misstatement, whether due to error or fraud. The Separate Accounts are not required to have, nor were we engaged to perform, an audit of its internal control over financial reporting. As part of our audits we are required to obtain an understanding of internal control over financial reporting but not for the purpose of expressing an opinion on the effectiveness of the Separate Accounts' internal control over financial reporting. Accordingly, we express no such opinion.

Our audits included performing procedures to assess the risks of material misstatement of the financial statements and financial highlights, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statements and financial highlights. Our audits also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statements and financial highlights. Our procedures included confirmation of investments owned as of December 31, 2023, by correspondence with the custodian or mutual fund companies. We believe that our audits provide a reasonable basis for our opinion.

/s/ DELOITTE & TOUCHE LLP

Tampa, Florida
March 22, 2024

We have served as the Separate Accounts' auditor since 2000.

	BHFTII BlackRock Capital Appreciation Division		BHFTII Brighthouse/ Wellington Core Equity Opportunities Division		BHFTII T. Rowe Price Large Cap Growth Division		Invesco V.I. EQV International Equity Division
Assets:
Investments at fair value	$	1,375,938	$	812,397	$	2,373,163	$	1,774,763
Due from Metropolitan Tower Life Insurance Company		—		47		—		—
Total Assets		1,375,938		812,444		2,373,163		1,774,763
Liabilities:
Accrued fees		46		48		25		39
Due to Metropolitan Tower Life Insurance Company		136		—		77		59
Total Liabilities		182		48		102		98
Net Assets	$	1,375,756	$	812,396	$	2,373,061	$	1,774,665
Contract Owners' Equity
Net assets from accumulation units	$	1,375,756	$	812,396	$	2,329,755	$	1,774,665
Net assets from contracts in payout		—		—		43,306		—
Total Net Assets	$	1,375,756	$	812,396	$	2,373,061	$	1,774,665

	BHFTII BlackRock Capital Appreciation Division			BHFTII Brighthouse/ Wellington Core Equity Opportunities Division			BHFTII T. Rowe Price Large Cap Growth Division			Invesco V.I. EQV International Equity Division
Investment Income:
Dividends	$	510		$	11,191		$	—		$	3,413
Expenses:
Mortality and expense risk charges		15,416			9,760			26,262			21,519
Administrative charges		1,848			1,169			3,150			2,580
Total expenses		17,264			10,929			29,412			24,099
Net investment income (loss)		(16,754	)		262			(29,412	)		(20,686	)
Net Realized and Change in Unrealized Gains (Losses) on Investments:
Realized gain distributions		23,593			82,616			—			1,278
Realized gains (losses) on sale of investments		(3,005	)		(1,278	)		(15,471	)		17,459
Net realized gains (losses)		20,588			81,338			(15,471	)		18,737
Change in unrealized gains (losses) on investments		469,706			(34,165	)		801,941			259,379
Net realized and change in unrealized gains (losses) on investments		490,294			47,173			786,470			278,116
Net increase (decrease) in net assets resulting from operations	$	473,540		$	47,435		$	757,058		$	257,430

	BHFTII BlackRock Ultra-Short Term Bond Division						BHFTII Western Asset Management U.S. Government Division						Invesco V.I. Core Plus Bond Division
	2023			2022			2023			2022			2023			2022
Increase (Decrease) in Net Assets:
From Operations:
Net investment income (loss)	$	561		$	(2,955	)	$	251		$	246		$	3,993		$	(2,972	)
Net realized gains (losses)		483			(110	)		(480	)		(923	)		(2,262	)		(6,156	)
Change in unrealized gains (losses) on investments		5,672			3,162			1,175			(2,911	)		13,428			(54,410	)
Net increase (decrease) in net assets resulting from operations		6,716			97			946			(3,588	)		15,159			(63,538	)
Contract Transactions:
Purchase payments received from Contract owners		—			—			—			500			—			—
Net transfers (including fixed account)		(1,820	)		9,032			(34	)		(25	)		(65	)		7,226
Transfers for Contract benefits and terminations		(34,590	)		(10,037	)		(3,041	)		(20,868	)		(5,158	)		(59,608	)
Net increase (decrease) in net assets resulting from Contract transactions		(36,410	)		(1,005	)		(3,075	)		(20,393	)		(5,223	)		(52,382	)
Net increase (decrease) in net assets		(29,694	)		(908	)		(2,129	)		(23,981	)		9,936			(115,920	)
Net Assets:
Beginning of year		214,251			215,159			29,512			53,493			331,902			447,822
End of year	$	184,557		$	214,251		$	27,383		$	29,512		$	341,838		$	331,902

	BHFTII BlackRock Capital Appreciation Division						BHFTII Brighthouse/Wellington Core Equity Opportunities Division
	2023			2022			2023			2022
Increase (Decrease) in Net Assets:
From Operations:
Net investment income (loss)	$	(16,754	)	$	(18,584	)	$	262		$	179
Net realized gains (losses)		20,588			367,972			81,338			157,735
Change in unrealized gains (losses) on investments		469,706			(1,060,161	)		(34,165	)		(214,292	)
Net increase (decrease) in net assets resulting from operations		473,540			(710,773	)		47,435			(56,378	)
Contract Transactions:
Purchase payments received from Contract owners		—			—			—			—
Net transfers (including fixed account)		(6,331	)		(39,358	)		(3,835	)		42,025
Transfers for Contract benefits and terminations		(117,049	)		(189,222	)		(45,306	)		(87,263	)
Net increase (decrease) in net assets resulting from Contract transactions		(123,380	)		(228,580	)		(49,141	)		(45,238	)
Net increase (decrease) in net assets		350,160			(939,353	)		(1,706	)		(101,616	)
Net Assets:
Beginning of year		1,025,596			1,964,949			814,102			915,718
End of year	$	1,375,756		$	1,025,596		$	812,396		$	814,102

	BHFTII T. Rowe Price Large Cap Growth Division						Invesco V.I. EQV International Equity Division
	2023			2022			2023			2022
Increase (Decrease) in Net Assets:
From Operations:
Net investment income (loss)	$	(29,412	)	$	(30,176	)	$	(20,686	)	$	5,320
Net realized gains (losses)		(15,471	)		432,284			18,737			209,935
Change in unrealized gains (losses) on investments		801,941			(1,670,110	)		259,379			(615,050	)
Net increase (decrease) in net assets resulting from operations		757,058			(1,268,002	)		257,430			(399,795	)
Contract Transactions:
Purchase payments received from Contract owners		1,600			1,200			—			—
Net transfers (including fixed account)		(2,952	)		(11,835	)		9,917			(12,489	)
Transfers for Contract benefits and terminations		(102,087	)		(152,250	)		(92,405	)		(76,914	)
Net increase (decrease) in net assets resulting from Contract transactions		(103,439	)		(162,885	)		(82,488	)		(89,403	)
Net increase (decrease) in net assets		653,619			(1,430,887	)		174,942			(489,198	)
Net Assets:
Beginning of year		1,719,442			3,150,329			1,599,723			2,088,921
End of year	$	2,373,061		$	1,719,442		$	1,774,665		$	1,599,723

1. ORGANIZATION

General American Separate Account Twenty-Eight and General American Separate Account Twenty-Nine (the "Separate Accounts"), separate accounts of Metropolitan Tower Life Insurance Company (the "Company"), were established by the Board of Directors of General American Life Insurance Company ("GALIC") on May 28, 1992 to support operations of GALIC with respect to certain variable annuity contracts (the "Contracts"). Effective after the close of the New York Stock Exchange on April 27, 2018, GALIC merged with and into the Company while concurrently changing the state of domicile to Nebraska (the "Merger"). Upon the Merger, the Separate Account became a separate account of the Company. The Company is a direct wholly-owned subsidiary of MetLife, Inc., a Delaware corporation. The Separate Accounts are registered as unit investment trusts under the Investment Company Act of 1940, as amended, and are subject to the rules and regulations of the United States Securities and Exchange Commission, as well as the Nebraska Department of Insurance.

The Separate Accounts are divided into Divisions, each of which is treated as an individual accounting entity for financial reporting purposes. Each Division invests in shares of the corresponding fund or portfolio (with the same name) of registered investment management companies (the "Trusts"), which are presented below:

AIM Variable Insurance Funds (Invesco Variable Insurance Funds) ("Invesco V.I.")

Brighthouse Funds Trust II ("BHFTII")

The assets of each of the Divisions of the Separate Accounts are registered in the name of the Company. Under applicable insurance law, the assets and liabilities of the Separate Accounts are clearly identified and distinguished from the Company's other assets and liabilities. The portion of the Separate Accounts' assets applicable to the Contracts cannot be used for liabilities arising out of any other business conducted by the Company.

2. LIST OF DIVISIONS

Purchase payments, less any applicable charges, applied to the Separate Accounts are invested in one or more Divisions in accordance with the selection made by the Contract owner. The following Divisions had net assets as of December 31, 2023:

General American Separate Account Twenty-Eight

BHFTII BlackRock Ultra-Short Term Bond Division

BHFTII Western Asset Management U.S. Government Division

Invesco V.I. Core Plus Bond Division

General American Separate Account Twenty-Nine

BHFTII BlackRock Capital Appreciation Division

BHFTII Brighthouse/Wellington Core Equity Opportunities Division

BHFTII T. Rowe Price Large Cap Growth Division

Invesco V.I. EQV International Equity Division

3. SIGNIFICANT ACCOUNTING POLICIES

Basis of Accounting

The financial statements have been prepared in accordance with accounting principles generally accepted in the United States of America ("GAAP") applicable for variable annuity separate accounts registered as unit investment trusts, which follow the accounting and reporting guidance in Financial Accounting Standards Board Accounting Standards Codification ("ASC") Topic 946, Investment Companies.

3. SIGNIFICANT ACCOUNTING POLICIES — (Continued)

Security Transactions

Security transactions are recorded on a trade date basis. Realized gains and losses on the sales of investments are computed on the basis of the average cost of the investment sold. Income from dividends and realized gain distributions are recorded on the ex-distribution date.

Security Valuation

A Division's investment in shares of a fund or portfolio of the Trusts is valued at fair value based on the closing net asset value ("NAV"). All changes in fair value are recorded as changes in unrealized gains (losses) on investments in the statements of operations of the applicable Divisions. The Separate Accounts define fair value as the price that would be received to sell an asset or paid to transfer a liability (an exit price) in the principal or most advantageous market for the asset or liability in an orderly transaction between market participants on the measurement date. Each Division invests in shares of open-end mutual funds which calculate a daily NAV based on the fair value of the underlying securities in their portfolios. As a result, and as required by law, shares of open-end mutual funds are purchased and redeemed at their daily NAV as reported by the Trusts at the close of each business day.

ASC Topic 820, Fair Value Measurement ("ASC 820") provides that the Separate Accounts are not required to categorize within the fair value hierarchy all investments for which fair value is measured using the NAV per share practical expedient. Additionally, ASC 820 does not require certain disclosures for all investments that are eligible to be measured at fair value using the NAV per share practical expedient. The Separate Accounts' investments in shares of a fund or portfolio of the Trusts are using NAV as a practical expedient, therefore investments are not categorized within the ASC 820 fair value hierarchy.

Federal Income Taxes

The operations of the Separate Accounts form a part of the total operations of the Company and are not taxed separately. The Company is taxed as a life insurance company under the provisions of the Internal Revenue Code ("IRC"). Under the current provisions of the IRC, the Company does not expect to incur federal income taxes on the earnings of the Separate Accounts to the extent the earnings are credited under the Contracts. Accordingly, no charge is currently being made to the Separate Accounts for federal income taxes. The Company will periodically review the status of this policy in the event of changes in the tax law. A charge may be made in future years for any federal income taxes that would be attributable to the Contracts.

Annuity Payouts

Net assets allocated to Contracts in the annuity payout period are computed according to industry standard mortality tables and, if any, are shown in net assets from Contracts in payout on the statements of assets and liabilities. The assumed investment return is 4.0 percent. The mortality risk is fully borne by the Company and may result in additional amounts being transferred into the Separate Accounts by the Company to cover greater longevity of annuitants than expected. Conversely, if amounts allocated exceed amounts required, transfers may be made to the Company. Annuity payouts, if any, are included in transfers for Contract benefits and terminations on the statements of changes in net assets of the applicable Divisions.

Purchase Payments

Purchase payments received from Contract owners by the Company are credited as accumulation units as of the end of the valuation period in which received, as provided in the prospectus for the Contracts, and are reported as Contract transactions on the statements of changes in net assets of the applicable Divisions.

Net Transfers

Assets transferred by the Contract owner into or out of Divisions within the Separate Accounts or into or out of the fixed account, which is part of the Company's general account, are recorded on a net basis as net transfers in the statements of changes in net assets of the applicable Divisions.

3. SIGNIFICANT ACCOUNTING POLICIES — (Concluded)

Use of Estimates

The preparation of financial statements in accordance with GAAP requires management to make estimates and assumptions that affect amounts reported herein. Actual results could differ from these estimates.

4. EXPENSES & CONTRACT CHARGES

The following annual Separate Accounts charge paid to the Company is an asset-based charge assessed through a daily reduction in unit values, which are recorded as administrative charges in the accompanying statements of operations of the applicable Divisions:

Administrative — The Company has responsibility for the administration of the Contracts and the Separate Accounts. Generally, the administrative charge is related to the maintenance of each Contract and the Separate Accounts.

The following annual Separate Accounts charge paid to the Company is an asset-based charge assessed through a daily reduction in unit values and are recorded as expenses in the accompanying statements of operations of the applicable Divisions:

Mortality and Expense Risk — The mortality risk assumed by the Company is the risk that those insured may die sooner than anticipated and therefore, the Company will pay an aggregate amount of death benefits greater than anticipated. The expense risk assumed is the risk that expenses incurred in issuing and administering the Contracts will exceed the amounts realized from the administrative charges assessed against the Contracts. In addition, the charge compensates the Company for the risk that the insured (the annuitant) may live longer than estimated and the Company would be obligated to pay more in income payments than anticipated.

The table below represents the effective annual rates for each respective charge for the year ended December 31, 2023:

Administrative					0.15	%
Mortality and Expense Risk					1.25	%

The above referenced charges may not necessarily correspond to the costs associated with providing the services or benefits indicated by the designation of the charge or associated with a particular Contract.

Separate Accounts charges referred to in this disclosure are for current charges of the Contracts and can vary among products within the Separate Accounts. A Contract administrative charge of $30 or 2% of the accumulated Contract value, whichever is less, is assessed on an annual basis for Contracts with an accumulated value of less than $20,000. The Company is currently waiving the transfer fee of the lesser of $25 or 2% of the transfer amount which is assessed after twelve transfers within a Contract year, but reserves the right to impose such charges in the future. These charges are paid to the Company and recorded as Contract charges in the accompanying statements of changes in net assets of the applicable Divisions for the years ended December 31, 2023 and 2022.

In addition, most Contracts impose a surrender charge which ranges from 0% to 6% if the Contract is partially or fully surrendered within the specified surrender charge period. These charges are paid to the Company, assessed through redemption of units, and recorded as Contract charges in the accompanying statements of changes in net assets of the applicable Divisions for the years ended December 31, 2023 and 2022. There were no such charges for the years ended December 31, 2023 and 2022.

6. SCHEDULES OF UNITS
For the years ended December 31, 2023 and 2022:

	General American Separate Account Twenty-Eight
	BHFTII BlackRock Ultra-Short Term Bond Division						BHFTII Western Asset Management U.S. Government Division						Invesco V.I. Core Plus Bond Division
	2023			2022			2023			2022			2023			2022
Units beginning of year		14,728			14,796			1,434			2,332			13,028			14,814
Units issued and transferred from other funding options		—			757			—			372			—			726
Units redeemed and transferred to other funding options		(2,481	)		(825	)		(148	)		(1,270	)		(209	)		(2,512	)
Units end of year		12,247			14,728			1,286			1,434			12,819			13,028
	General American Separate Account Twenty-Nine
	BHFTII BlackRock Capital Appreciation Division						BHFTII Brighthouse/ Wellington Core Equity Opportunities Division						BHFTII T. Rowe Price Large Cap Growth Division
	2023			2022			2023			2022			2023			2022
Units beginning of year		28,808			33,956			26,641			28,049			46,076			49,562
Units issued and transferred from other funding options		81			912			43			2,341			157			637
Units redeemed and transferred to other funding options		(2,697	)		(6,060	)		(1,643	)		(3,749	)		(2,309	)		(4,123	)
Units end of year		26,192			28,808			25,041			26,641			43,924			46,076

	General American Separate Account Twenty-Nine
	Invesco V.I. EQV International Equity Division
	2023			2022
Units beginning of year		62,284			65,520
Units issued and transferred from other funding options		464			1,573
Units redeemed and transferred to other funding options		(3,442	)		(4,809	)
Units end of year		59,306			62,284

7. FINANCIAL HIGHLIGHTS

The following table is a summary of unit values and units outstanding for the Contracts, net assets, net investment income ratios, expense ratios, excluding expenses for the underlying portfolio or fund, and total return ratios for the five years ended December 31, 2023:

		As of December 31						For the year ended December 31
		Units		Unit Value ($)		Net Assets ($)		Investment¹Income Ratio (%)		Expense²Ratio (%)		Total³Return (%)
General American Separate Account Twenty-Eight
BHFTII BlackRock	2023		12,247		15.07		184,557		1.69		1.40		3.59
Ultra-Short Term Bond	2022		14,728		14.55		214,251		—		1.40		0.04
Division	2021		14,796		14.54		215,159		0.34		1.40		(1.58	)
	2020		15,383		14.78		227,299		1.93		1.40		(0.97	)
	2019		16,708		14.92		249,283		1.61		1.40		0.71
BHFTII Western Asset	2023		1,286		21.29		27,383		2.33		1.40		3.41
Management U.S. Government	2022		1,434		20.59		29,512		2.14		1.40		(10.27	)
Division	2021		2,332		22.94		53,493		2.69		1.40		(2.89	)
	2020		2,405		23.63		56,825		2.96		1.40		3.78
	2019		3,227		22.77		73,464		2.76		1.40		4.56
Invesco V.I. Core Plus Bond	2023		12,819		26.67		341,838		2.59		1.40		4.67
Division	2022		13,028		25.48		331,902		0.57		1.40		(15.72	)
	2021		14,814		30.23		447,822		1.46		1.40		(2.04	)
	2020		16,882		30.86		520,930		2.05		1.40		8.19
	2019		14,414		28.52		411,109		2.86		1.40		9.52
General American Separate Account Twenty-Nine
BHFTII BlackRock Capital	2023		26,192		52.53		1,375,756		0.04		1.40		47.54
Appreciation Division	2022		28,808		35.60		1,025,596		—		1.40		(38.48	)
	2021		33,956		57.87		1,964,949		—		1.40		19.52
	2020		35,570		48.42		1,722,213		—		1.40		38.70
	2019		41,002		34.91		1,431,249		0.22		1.40		31.01
BHFTII	2023		25,041		32.44		812,396		1.43		1.40		6.17
Brighthouse/Wellington Core	2022		26,641		30.56		814,102		1.42		1.40		(6.40	)
Equity Opportunities Division	2021		28,049		32.65		915,718		1.41		1.40		22.70
	2020		32,650		26.61		868,746		1.58		1.40		9.72
	2019		39,351		24.25		954,302		1.64		1.40		29.12
BHFTII T. Rowe Price Large	2023		43,924		54.03		2,373,061		—		1.40		44.78
Cap Growth Division	2022		46,076		37.32		1,719,442		—		1.40		(41.29	)
	2021		49,562		63.56		3,150,329		—		1.40		18.55
	2020		53,185		53.62		2,851,614		0.25		1.40		35.04
	2019		67,637		39.70		2,685,378		0.43		1.40		29.17
Invesco V.I. EQV	2023		59,306		29.92		1,774,665		0.20		1.40		16.51
International Equity Division	2022		62,284		25.68		1,599,723		1.71		1.40		(19.44	)
	2021		65,520		31.88		2,088,921		1.25		1.40		4.42
	2020		70,700		30.53		2,158,714		2.36		1.40		12.41
	2019		81,691		27.16		2,219,013		1.58		1.40		26.79

1 These amounts represent the dividends, excluding distributions of capital gains, received by the Division from the underlying fund or portfolio, net of management fees assessed by the fund manager, divided by the average net assets. These ratios exclude those expenses, such as mortality and expense risk charges, that are assessed against Contract owner accounts either through reductions in the unit values or the redemption of units. The investment income ratio is calculated for each period indicated or from the effective date through the end of the reporting period. The recognition of investment income by the Division is affected by the timing of the declaration of dividends by the underlying fund or portfolio in which the Division invests.

2 These amounts represent annualized Contract expenses of each of the Separate Accounts, consisting primarily of mortality and expense risk charges, for each period indicated. The ratios include only those expenses that result in a direct reduction to unit values. Charges made directly to Contract owner accounts through the redemption of units and expenses of the underlying fund or portfolio have been excluded.

3 These amounts represent the total return for the period indicated, including changes in the value of the underlying fund or portfolio, and expenses assessed through the reduction of unit values. These ratios do not include any expenses assessed through the redemption of units. The total return is calculated for each period indicated or from the effective date through the end of the reporting period.

	As of December 31, 2023				For the year ended December 31, 2023
	Shares		Cost ($)		Cost of Purchases ($)		Proceeds from Sales ($)
General American Separate Account Twenty-Eight
BHFTII BlackRock Ultra-Short Term Bond Division		1,765		177,919		3,250		39,080
BHFTII Western Asset Management U.S. Government Division		2,599		30,688		672		3,478
Invesco V.I. Core Plus Bond Division		59,556		404,748		8,641		9,830
General American Separate Account Twenty-Nine
BHFTII BlackRock Capital Appreciation Division		37,967		1,250,347		26,679		143,073
BHFTII Brighthouse/Wellington Core Equity Opportunities Division		28,485		836,606		94,756		61,037
BHFTII T. Rowe Price Large Cap Growth Division		114,646		2,305,301		3,779		136,576
Invesco V.I. EQV International Equity Division		52,061		1,401,310		15,887		117,695

	BHFTII BlackRock Ultra-Short Term Bond Division		BHFTII Western Asset Management U.S. Government Division		Invesco V.I. Core Plus Bond Division
Assets:
Investments at fair value	$	184,564	$	27,393	$	341,851
Due from Metropolitan Tower Life Insurance Company		35		33		28
Total Assets		184,599		27,426		341,879
Liabilities:
Accrued fees		42		43		41
Due to Metropolitan Tower Life Insurance Company		—		—		—
Total Liabilities		42		43		41
Net Assets	$	184,557	$	27,383	$	341,838
Contract Owners' Equity
Net assets from accumulation units	$	184,557	$	27,383	$	341,838
Net assets from contracts in payout		—		—		—
Total Net Assets	$	184,557	$	27,383	$	341,838