August 24, 2018

Siddhartha Sankaran
Executive Vice President and Chief Financial Officer
175 Water Street
New York, New York 10038

           Form 10-K for the Year Ended December 31, 2017
           Filed February 16, 2018
           File No. 001-08787

Dear Mr. Sankaran:

        We have reviewed your July 9, 2018 response to our comment letter 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
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

       After reviewing your response to the comment, we may have additional
comments. Unless we note otherwise, our references to the prior comment is the
comment in our
June 15, 2018 letter.

Form 10-K for the Year Ended December 31, 2017

Notes to Consolidated Financial Statements
13. Insurance Liabilities
Liability for Unpaid Losses and Loss Adjustment Expenses (Loss Reserves)
Loss Development Information
Supplemental Information , page 237

1.     We acknowledge the information provided in your response as well as the
       disclosure discussed in our call on August 7, 2018. Please provide us
with proposed
       disclosure in total to be included in your next Form 10-K, revised from
that included on
       page 10 in your response, to address the following for the US Excess
Casualty line of
 Siddhartha Sankaran
August 24, 2018
Page 2
         business representing an example of the disclosure that you will
provide for all six lines of
         business subject to the Adverse Development Reinsurance agreement:
           Explain specifically how the amounts in the "U.S. Excess Casualty
Table, Net of ADC
            Impact" shown on page 10 of your response were derived from the
"US. Excess
            Casualty (existing Table in our 2017 Form 10-K)" also shown on page
10 and from the
            table to be included as a result of the next bullet.
           A table showing attribution of the reinsurance recoverable under the
            Development Reinsurance agreement by accident year beginning with
the 2016
            calendar year.
           Include a discussion as a note to the table referred to in the
preceding bullet or a cross
            reference to a discussion that addresses the method used to
allocate your reinsurance
            recoverable under the Adverse Development Reinsurance Agreement to
each of the
            accident years within the six lines of business and to explain the
factors that may cause
            these allocations to change. In this regard, your response to our
previous comment that
            you addressed on pages 14 and 15 will suffice, if revised to
clearly convey that the
            allocations are re-estimated at the end of each period and to
highlight the factors that
            cause the allocations to change.
       You may contact Frank Wyman at 202-551-3660 or Jim Rosenberg at
202-551-3679 with
any questions.

FirstName LastNameSiddhartha Sankaran    Sincerely,
                                         Division of Corporation Finance
August 24, 2018 Page 2                   Office of Healthcare & Insurance
FirstName LastName