We report the first reflection modulator using electroabsorption in strained InGaAs-GaAs quantum wells. With an insertion loss of 1.9 dB and a reflectivity change of 42% at room temperature, the modulator is comparable to the best devices reported in the GaAs-AlGaAs system. We also describe a framework to examine the tradeoff between insertion loss and modulation ratio from a theoretical perspective and compare the predicted limits to reported devices.