June 15, 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 April 10, 2018 response to our comment letter and
have the
following comment. In our comment, we 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 prior comments are to
comments in our
March 28,2018 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.    Please refer to your response to our prior comment 2. We continue to
believe that ASC
      944-40-50-4B requires disclosure in a tabular format, as of the date of
your latest annual
      balance sheet presented, undiscounted information about claims
development by accident
      year on a net basis after risk mitigation through reinsurance. That is,
the effects of risk
 Siddhartha Sankaran
June 15, 2018
Page 2
         mitigation are depicted by accident year for each calendar year of the
table, not simply the
         most recent calendar year. While we appreciate that there are unique
aspects to your
         Adverse Development Reinsurance Agreement and understand that your
depiction of
         claims development on a gross basis provides useful information, we
note that your
         current disclosure does not appear to comply with this requirement.
Please propose
         incremental tabular disclosure that depicts as of your latest annual
balance sheet date
         undiscounted information about your reinsurance recoverable by
accident year for the
         number of years depicted in your existing tables. Also propose
disclosure to describe the
         method used to allocate your reinsurance recoverable under the Adverse
         Reinsurance Agreement to the six lines of business to which it relates
and to explain the
         factors that may cause these allocations to change, as disclosure
within the "Reinsurance"
         factor on page 237 is vague.
       You may contact Frank Wyman at 202-551-3660 or Jim Rosenberg at
202-551-3679 if
you have questions.

FirstName LastNameSiddhartha Sankaran
                                         Division of Corporation Finance
June 15, 2018 Page 2                     Office of Healthcare & Insurance
FirstName LastName