March 28, 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 limited our review of your filing to the financial statements
and related
disclosures and have the following comments. In some of our comments, we may
ask you to
provide us with information so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your

       After reviewing your response to these comments, we may have additional

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

Item 1A Risk Factors
The USA Patriot Act, the Office of Foreign Assets Control and similar laws that
apply to us may
expose us to significant penalties, page 26

1.    In your letter to us dated January 15, 2015, you discussed possible
contacts with Syria and
      Sudan. As you are aware, Syria and Sudan are designated by the State
Department as
      state sponsors of terrorism and are subject to U.S. economic sanctions
and/or export
      controls. You do not provide disclosure about Syria or Sudan in your Form
10-K. Please
      describe to us the nature and extent of any past, current, and
anticipated contacts with
      Syria or Sudan since your 2015 letter, including contacts with their
governments, whether
      through subsidiaries, re-insurers, clients, brokers, affiliates, or other
direct or indirect
      arrangements. Please also discuss the materiality of any contacts in
quantitative terms and
 Siddhartha Sankaran
March 28, 2018
Page 2
         in terms of qualitative factors that a reasonable investor would deem
important in making
         an investment decisions. Tell us the approximate dollar amounts of any
revenues, assets,
         and liabilities associated with Syria or and Sudan for the last three
fiscal years and the
         subsequent interim period. Address the potential impact of the
investor sentiment
         evidenced by divestment and similar initiatives that have been
directed toward companies
         that have operations associated with U.S.-designated state sponsors of
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

2.       Please provide us an analysis supporting your presentation of the
Adverse Development
         Reinsurance Agreement as a separate column rather than reflecting its
impact for each
         year within each accident year within the development tables. Guidance
in ASC 944-40-
         50-4B indicates that amounts in the tables for incurred/paid claims
and allocated claim
         adjustment expenses should be presented on a net basis after risk
mitigation through
         reinsurance. In addition, tell us the terms governing NICO's payment
obligations under
         the agreement. In this regard, there does not appear to have been any
payments to you
         from NICO during 2017 based on information in the column "paid impact
of Adverse
         Development Reinsurance Agreement" within the tables titled
"cumulative paid losses and
         allocated loss adjustment expenses, net of reinsurance."
       In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.

       You may contact Frank Wyman at 202-551-3660 or Jim Rosenberg at
202-551-3679 with
any questions.

FirstName LastNameSiddhartha Sankaran
                                         Division of Corporation Finance
June 16, 2017 Page 2                     Office of Healthcare & Insurance
FirstName LastName