Form: CORRESP

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August 18, 2006














                           [RenRe Holdings Letterhead]





August 18, 2006


VIA EDGAR
- ---------


Mr. James B. Rosenberg
Senior Assistant Chief Accountant
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 6010
100 F Street, NE
Washington, D.C. 20549


Re:    RenaissanceRe Holdings Ltd.
       Form 10-K for Fiscal Year Ended December 31, 2005
       File No. 1-14428


Dear Mr. Rosenberg:

On behalf of RenaissanceRe Holdings Ltd. (the "Company"), I am responding to the
comments of the staff (the "Staff") of the Securities and Exchange Commission
(the "Commission") pertaining to the Company's Form 10-K for the fiscal year
ended December 31, 2005, filed March 3, 2006 (the "Form 10-K"), and contained in
the letter, dated July 28, 2006 (the "Comment Letter").

I have set forth each of the Staff's comments below with the Company's
corresponding response and have numbered the items to correspond to the Comment
Letter.

Defined terms used herein without definition have the meanings ascribed to them
in the Form 10-K.



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August 18, 2006
Page 2


FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2005

Management's Discussion and Analysis of Financial Condition and Results of
Operations
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Summary of Critical Accounting Estimates
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Claims and Claim Expense Reserves, page 64
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We believe your disclosure regarding the estimation of the reserve for claims
and claim expenses could be improved to better explain the judgments and
uncertainties surrounding this estimate and the potential impact on your
financial statements. We believe in order to meet the principal objectives of
MD&A this disclosure should enable the investor to understand 1) management's
method for establishing the estimate; 2) whether and if so to what extent and
why management has adjusted their assumptions used to determine the estimate
from the assumptions used in the immediately preceding period; and 3) the
potential variability in the most recent estimate and the impact this
variability may have on reported results, financial condition and liquidity.
Please keep these points in mind in providing us your responses to the comments
listed below. Please provide us, in a disclosure-type format, the following
information for each material line of business and also consider providing any
additional information to achieve this objective.

1.   We acknowledge your use of the Bornhuetter-Ferguson technique to estimate
     your claims and claim expenses reserve in your specialty reinsurance and
     Individual Risk operations. Please describe the methods you used to
     determine your reserve for claims and claim expenses in your other lines of
     business. Please ensure this description:

     a.   Explains how the methods you use for your short-tail business differ
          from the methods you use for your long-tail business.

     b.   Identifies the unique development characteristics of each material
          short-tail and long-tail line of business.

     c.   Describes the method you used to calculate the IBNR reserve for each
          material line of business. For example, we understand that some
          companies may calculate this reserve by estimating the ultimate unpaid
          liability first and then reducing that amount by cumulative paid
          claims and by case reserves, but there may be other methods as well.

     d.   Clarifies how you complete your quarterly reserve review. In this
          regard, please indicate which assumptions and methodologies you review
          on a quarterly basis.

     RESPONSE:

     a.   The Company's only other line of business is property catastrophe
          reinsurance. This line of business is short-tail business. Please
          refer to Exhibit A for additional disclosure the Company will include
          in its Claims and Claim Expense Reserves Critical Accounting Estimates
          discussion in its next quarterly report on Form 10-Q and its next




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August 18, 2006
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          Annual Report on Form 10-K that further clarifies that this business
          is short-tail. Since all of the Company's property catastrophe
          reinsurance is short-tail, we believe a comparison to long-tail
          business within this line is not applicable.

     b.   The Company's property catastrophe reinsurance business principally
          consists of excess of loss property catastrophe reinsurance contracts
          sold to insurance companies and other reinsurance companies to
          provide these companies with reinsurance protection against natural
          and man-made catastrophes. Claims and claim expense reserves for this
          line of business are estimated by management after an event occurs by
          completing an in-depth review of the individual policies potentially
          impacted by the catastrophic event. The objective of this review is
          to estimate the ultimate expected cost to settle all claims and
          administrative costs arising from catastrophic events that have
          occurred as of the latest balance sheet date.

          The events from which claims arise under these contracts are typically
          prominent, public occurrences such as hurricanes, earthquakes and
          other natural and man-made catastrophes. These events are generally
          known shortly after they occur. This business is generally
          characterized by loss events of low frequency and high severity. In
          general, reporting of claims from these events tends to be relatively
          prompt. However, the timing of claims reporting does vary depending on
          various factors, including: whether the claims arise under reinsurance
          of primary companies or reinsurance of other reinsurance companies;
          the nature of the events (e.g., hurricanes, earthquakes and other
          natural and man-made catastrophes); the geographic area involved; the
          size of insured industry losses arising from the event; and the
          quality of each customer's claims management and reserving practices.

          In addition to loss information and estimates communicated to the
          Company by its cedants, the Company uses industry information and
          client exposure information which it gathers and retains in its REMS
          modeling system to assist it in developing its reserves for claims and
          claim expenses. When property catastrophe losses do occur, the
          information stored in the Company's REMS modeling system enables
          management to analyze each of the Company's policies against such loss
          and compare its estimates of the loss with those reported by its
          cedants. The REMS modeling system also allows the Company to compare
          and analyze individual losses reported by its cedants affected by the
          same loss event. Although the REMS modeling system assists with the
          analysis of the underlying loss, and provides the Company with the
          information and ability to perform increased analysis, the estimation
          of claims resulting from catastrophic events is inherently difficult
          because of the variability and uncertainty associated with property
          catastrophe claims and the unique characteristics of each loss.

          The items discussed above represent the unique characteristics which
          the Company considers when estimating its reserves for claims and
          claim expenses for its property catastrophe reinsurance business.
          This information is included in the Company's







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          Claims and Claim Expense Reserves Critical Accounting Estimates
          discussion in its Annual Report on Form 10-K and quarterly reports on
          Form 10-Q.

     c.   Please refer to Exhibit B for additional disclosure the Company will
          include in its Claims and Claim Expense Reserves Critical Accounting
          Estimates discussion in its next quarterly report on Form 10-Q and its
          next Annual Report on Form 10-K that further describes the methods
          used to calculate IBNR for the Company's property catastrophe
          reinsurance business.

     d.   Please refer to Exhibit C for additional disclosure the Company will
          include in its Claims and Claim Expense Reserves Critical Accounting
          Estimates discussion in its next quarterly report on Form 10-Q and its
          next Annual Report on Form 10-K that further describes the Company's
          quarterly reserve review process.

2.   Please discuss the reserving process to specifically indicate the
     relationship between your internal actuarial estimates, your annual review
     by an independent actuarial firm and management's best estimate of the
     reserve for claims and claim expenses. In this regard, if management has
     added an incremental provision to the reserve for claims and claim
     expenses determined by your actuaries, quantify the incremental provision,
     describe the method used by management to determine it and the extent to
     which that method differs from period to period, and identify and analyze
     the specific underlying reasons that explain why you believe it is
     necessary.

     RESPONSE: The Company's reserving methodology for each line of business
     uses a process that calculates a point estimate for the Company's ultimate
     expected losses. The Company itself does not calculate a range of
     estimates. The Company uses this point estimate, along with paid and
     reported data, to record its best estimate of incurred but not reported
     reserves ("IBNR") in the Company's financial statements. There is no
     incremental provision added to or deducted from the Company's point
     estimate when calculating its claims and claim expense reserves. The
     Company's point estimate is what is recorded in the Company's financial
     statements.

     The Company's claims and claim expense reserves are reviewed annually by an
     independent actuarial firm. The actuarial firm performs this work for the
     purpose of issuing an actuarial opinion on the reasonableness of the
     Company's claims and claim expense reserves for each of the Company's
     reinsurance and insurance subsidiaries. The actuarial opinions are required
     to meet various insurance regulatory requirements. The actuarial firm
     discusses their conclusions with management and presents their findings to
     management and the Audit Committee of the Board of Directors of the
     Company. Although the Company does not explicitly rely on the work
     performed by the actuarial firm for estimating its reserves for claims and
     claim expenses, the Company compares its recorded claims and claim expense
     reserves to those estimated by the actuarial firm to ensure the Company's
     estimates are within the actuarial firm's reasonable range of estimates. To
     date, the Company's estimates of claims and claim expense reserves for each
     relevant period have





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August 18, 2006
Page 5


     been within the actuarial firm's reasonable range of estimates. The Company
     will include additional disclosure in its Claims and Claim Expense Reserves
     Critical Accounting Estimates discussion in its next quarterly report on
     Form 10-Q and its next Annual Report on Form 10-K that includes the items
     discussed above. Please refer to Exhibit D for illustration of such
     proposed disclosure.

3.   You disclose here, in Business on pages 18 through 21, and elsewhere the
     significant revisions to your estimates of claims and claim expenses
     reserves recorded in prior years for your property catastrophe portfolio
     and your specialty reinsurance business. Although you identify the products
     involved and the accident years, you do not appear to explain why you
     revised your estimates. Please identify and describe in reasonable
     specificity the nature and extent of new events that occurred or additional
     experience/information obtained since the last reporting date that led to
     the change in estimates. In this regard, please describe the material
     differences in the key assumptions experienced compared to those used in
     your prior reserve estimates. Please ensure your discussion clarifies the
     timing of the change in estimate such as why recognition occurred in the
     periods that it did and why recognition in earlier periods was not
     required.

     RESPONSE: The Company announced in its March 31, 2005 quarterly report on
     Form 10-Q that with the growth in the Company's reserves for claims and
     claim expenses, management would perform a review of the processes and
     assumptions for establishing and evaluating the Company's reserves. The
     Company describes these reserve reviews in its 2005 Form 10-K in several
     places including in Item 1, Business, Item 7, Management's Discussion and
     Analysis of Financial Condition and Results of Operations, Item 8,
     Financial Statements and Supplementary Data and Item 9A, Controls and
     Procedures. The Company quantifies the impact of these reviews on the
     Company's net claims and claim expense reserves and its net loss for the
     year. This disclosure supplements disclosure previously made in the
     Company's quarterly reports on Form 10-Q for the quarters ending March 31,
     2005, June 30, 2005 and September 30, 2005.

     The decision to perform the additional reserve reviews in 2005, rather than
     in an earlier period was principally due to: 1) the growth in the Company's
     specialty reinsurance and Individual Risk businesses which resulted in a
     significant increase in reserves for claims and claim expenses for these
     lines of business; 2) an increase in then-recent periods in favorable
     development in the Company's reserves in its specialty reinsurance and
     Individual Risk businesses, which had performed more favorably, in what was
     effectively their first three years of operations, than historical industry
     data would have anticipated; 3) recent favorable development with respect
     to the Company's property catastrophe reinsurance reserves; and 4) a
     determination to consider enhancements to the Company's reserving processes
     and assumptions.

     The Company reviews its reserves for claims and claim expenses quarterly
     and changes in its estimates are recorded in the period in which they
     occur. Prior to the reserve reviews,






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     the Company's previous estimates for claims and claim expenses reflected
     the Company's best estimates at each previous reporting period.

     The Company significantly expanded its specialty reinsurance and
     Individual Risk businesses in 2002 after pricing and terms started
     improving in these markets in late 2001. When establishing the Company's
     reserves for these new lines of business, the Company placed significant
     reliance on industry data as it did not have the benefit of its own
     historical experience. The Company believes that reliance on this industry
     information can lead to greater uncertainty as to ultimate expected losses
     for these lines of business. In addition, much of the specialty
     reinsurance business the Company writes includes providing large limits on
     high layer catastrophe exposed business which makes this line of business
     more volatile than most other lines, such as primary insurance or quota
     share reinsurance of primary lines. The large limits provided to clients
     also means the business will likely deviate more significantly from
     expected results than other lines as the experience on a small number of
     contracts can significantly influence the overall results.

     The Company's property catastrophe reinsurance business is also more
     volatile than more traditional primary insurance or quota share
     reinsurance of primary lines as changes to reported losses on large
     catastrophes by the Company's cedants have the potential to significantly
     increase or decrease the Company's reserves for claims and claim expenses.
     The events giving rise to these large losses are typically prominent,
     public occurrences such as hurricanes, earthquakes and other natural and
     man-made catastrophes, which tend to result in contractual and legal
     issues that often take many years to resolve. As described in the
     Company's filings, the Company's actual losses from these events will
     likely vary, perhaps materially, from these current estimates due to the
     inherent uncertainties in reserving for large catastrophes, including the
     preliminary nature of the available information, the potential
     inaccuracies and inadequacies in the data provided by clients and brokers,
     the inherent uncertainty of modeling techniques and the application of
     such techniques, the effects of any demand surge on claims activity and
     complex coverage and other legal issues.

     With the passage of time, the Company started experiencing some favorable
     development on the run-off of the Company's reserves. This favorable
     development was principally due to the Company's specialty and Individual
     Risk businesses performing better than historical industry data. In
     addition, paid and reported losses were developing better than expected in
     the Company's property catastrophe reinsurance business. Prior to the
     announcement of the reserve reviews in early 2005, the Company had not
     determined there was a persistent recurring trend in the development of its
     reserves for claims and claim expenses that required it to perform
     additional reviews over and above its normal quarterly and annual reserving
     procedures. For example, the Company's reserves had developed both
     favorably and unfavorably with respect to individual prior catastrophic
     loss events.

     The disclosure in the Company's quarterly reports on Form 10-Q and its
     2005 Annual Report on Form 10-K describes the reason for the reserve
     changes. The decrease in net claims and claim expenses for the Company's
     property catastrophe reinsurance business was principally due to
     management re-estimating the ultimate expected losses for both








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     small catastrophes and large catastrophes. This was due to a reassessment
     of reserves for claims and claim expenses in light of historical paid loss
     trends and reported loss activity for these catastrophes. In coming to this
     conclusion, the Company reviewed claims files, requested updated claims
     information from its clients and brokers, and developed some new tools to
     help assess trends in paid and reported losses. As a result of this review,
     the Company determined that there were credible trends of paid and reported
     claims for these catastrophes that were coming in less than originally
     expected and therefore the ultimate expected losses for these catastrophes
     were decreased.

     The review also included a reassessment of the Company's actuarial
     techniques and assumptions for its specialty reinsurance business. The
     Company considered whether or not it should continue with the use of the
     Bornhuetter-Ferguson actuarial method in reserving for its specialty
     reinsurance business or whether a different actuarial method might be more
     appropriate. As a result of the review, the Company determined it was
     appropriate to continue with the use of the Bornhuetter-Ferguson actuarial
     method. This method is appropriate for lines of business, such as the
     Company's specialty reinsurance business, where there is a lack of
     historical claims experience. It also assumes that past experience is not
     necessarily fully representative of the future. In addition, it has the
     benefit of placing more weight on actual experience and less on expected
     experience as the Company's reserves for claims and claim expenses age.

     To enhance the reserving for the Company's specialty reinsurance business,
     the Company further segmented this business during the review with the aim
     of grouping risks into more homogeneous categories which respond to the
     evolution of actual exposures. This became possible as the volume of
     business increased over the three preceding years. This further
     segmentation required the selection of loss reporting patterns to be
     applied to these new classes. The Company also updated its assumptions for
     its original loss reporting patterns based on a combination of new
     industry information and actual experience accumulated over the three
     preceding years. The assumptions for the new loss reporting patterns were
     applied to all prior underwriting years. In addition, the Company made
     explicit allowances for commuted contracts whereas previously these were
     considered in the overall reserving assumptions. The Company also reviewed
     substantially all of its case reserves and additional case reserves. The
     result of the foregoing was a decrease in the Company's specialty
     reinsurance reserves for claims and claim expenses as noted above.

     The Company's reserve review for its Individual Risk business followed a
     similar process to the specialty reinsurance review noted above. The
     changes within the Company's Individual Risk segment as a result of the
     reserve review were insignificant.

     The Company will include additional disclosure in its Claims and Claim
     Expense Reserves Critical Accounting Estimates discussion in its next
     quarterly report on Form 10-Q and its next Annual Report on Form 10-K that
     provides additional information on these reserve reviews. Please refer to
     Exhibit E for this disclosure.





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4.   Please identify and describe those key assumptions that materially affect
     the estimate of the reserve for claims and claim expenses. In addition
     please address the following:

     a. For each of your key assumptions, quantify and explain what caused them
     to change from the assumptions used in the immediately preceding period.
     Please note that this discussion should supplement, rather than duplicate
     the disclosure provided responsive to Industry Guide 6.

     b. Explicitly identify and discuss key assumptions as of December 31, 2005
     that are premised on future emergence that are inconsistent with
     historical loss reserve development patterns and explain why the
     assumptions are now appropriate given the inconsistency identified.

     RESPONSE:

     a.   The Company estimates its IBNR for its Individual Risk and specialty
          reinsurance businesses by utilizing an actuarial technique known as
          the Bornhuetter-Ferguson method. The utilization of the
          Bornhuetter-Ferguson method requires the Company to estimate an
          expected ultimate claims and claim expense ratio and select an
          estimated loss reporting pattern. The Company selects its estimates of
          the expected ultimate claims and claim expense ratios and estimated
          loss reporting patterns by reviewing industry data and adjusting this
          data based upon the terms of the coverages it offers. As noted in the
          Company's Form 10-K, in reserving for the Company's specialty
          reinsurance and Individual Risk coverages, the Company does not have
          the benefit of a significant amount of its own historical experience
          in these lines. The key assumptions that changed in 2005 were the
          estimated loss development factors in the Company's specialty
          reinsurance business. As supplementally described above, the Company's
          reserves for claims and claim expenses for its property catastrophe
          reinsurance business are based on ground up estimates of the ultimate
          expected losses and were not impacted by these assumption changes.

          Please refer to Exhibit E for additional disclosure the Company will
          include in its Claims and Claim Expense Reserves Critical Accounting
          Estimates discussion in its next quarterly report on Form 10-Q and
          its next Annual Report on Form 10-K that provides additional
          information on the key assumptions and changes.

     b.   The Company does not believe its key assumptions are premised on
          future emergence that is inconsistent with its loss development.
          Because the Company does not have a significant amount of paid or
          reported claims information within its Individual Risk and specialty
          reinsurance businesses, the Company supplements its own historical
          experience with industry information when developing its estimates for
          reserves for claims and claim expenses. This industry information is
          principally used to assist the Company in developing its estimated
          loss development factors for use in the Bornhuetter-Ferguson actuarial
          reserving method. The Company believes that its





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          estimates for expected ultimate claims and claim expense ratios and
          loss reporting patterns represent its best estimate of the expected
          outcomes. Over time, the Bornhuetter-Ferguson actuarial method places
          less weight on expected experience and emphasizes actual experience.
          Therefore, as the Company's reserves age, the Company's estimates for
          IBNR are determined by its own experience, rather than industry
          experience.

     5. On page 22 you disclose the simple mathematical impact on earnings of a
     five percent increase in your additional case reserves and your IBNR
     reserves. We do not believe that this disclosure provides significant
     information to investors as they can calculate this impact on their own.
     We believe that management is in the unique position to provide investors
     with insights into the potential variability in the most recent estimate
     of your claims and claim expenses reserve. Therefore, please quantify and
     present preferably in a tabular format the impact that reasonably likely
     changes in the key assumptions identified may have on reported results,
     financial position and liquidity. Explain why you believe the scenarios
     quantified are reasonably likely.

     RESPONSE: The Company does not currently perform sensitivity analysis on
     its reserves for claims and claim expenses or utilize this type of analysis
     when estimating its reserves. The Company will, however, develop a process
     and procedures for performing sensitivity analysis around its actuarial
     assumptions and provide this information in future filings. The reserves
     for the Company's specialty reinsurance and Individual Risk businesses are
     established through the Bornhuetter-Ferguson actuarial method and are
     therefore subject to actuarial assumptions. The sensitivity analysis will
     include sensitivity analysis around the initial expected claims and claim
     expenses ratios and the estimated loss reporting patterns. We believe these
     represent the two principal actuarial assumptions used to estimate claims
     and claim expense reserves for these lines of business. The Company expects
     this disclosure will quantify in tabular format the impact on the Company's
     net income (loss) and shareholders' equity of changes to the initial
     expected claims and claim expense ratios and estimated loss reporting
     patterns by line of business. This analysis will replace the five
     percentage point change analysis for the Company's Individual Risk and
     specialty reinsurance businesses. The Company will continue to use an
     overall percentage point change sensitivity analysis for its property
     catastrophe reinsurance claims and claim expense reserves. As
     supplementally described elsewhere, the Company's reserves for claims and
     claim expenses for its property catastrophe reinsurance business are based
     on ground up estimates of the ultimate expected losses for each of the
     policies impacted by an event and these reserves are therefore not subject
     to the same actuarial assumption changes noted above. The Company will
     provide this sensitivity analysis in tabular format in its next Annual
     Report on Form 10-K.

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In connection with our response, the Company acknowledges:

     o    the Company is responsible for the adequacy and accuracy of the
          disclosure in its filings;

     o    Staff comments or changes to disclosure in response to Staff comments
          do not foreclose the Commission from taking any action with respect to
          the Company's filings; and

     o    the Company will not assert Staff comments as a defense in any
          proceeding initiated by the Commission or any other person under the
          federal securities laws of the United States.

I trust that the Company's responses to your comments meet with your approval.
Should you have any questions concerning this letter please call John S.
D'Alimonte of Willkie Farr & Gallagher LLP at (212) 728-8212 or the undersigned
at (441) 295-4513.


Very truly yours,

/s/ Mark A. Wilcox

Mark A. Wilcox
Senior Vice President
Corporate Controller and Chief Accounting Officer







cc:
Mr. Donald Abbott
Mr. Mark Brunhofer
Mr. Neill A. Currie
Mr. Fred R. Donner
Stephen H. Weinstein, Esq.
John S. D'Alimonte, Esq.








Securities and Exchange Commission
August 18, 2006
Page 11


                                    EXHIBIT A


For our property catastrophe reinsurance business, which is generally
characterized by loss events of low frequency and high severity, reporting of
claims in general tends to be prompt. We consider this business "short-tail" as
compared to reporting of claims for "long-tail" products, which tends to be
slower.




























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August 18, 2006
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                                    EXHIBIT B


For our property catastrophe reinsurance business, claims and claim expense
reserves are estimated by management after a catastrophe occurs by completing an
in-depth review of the individual polices potentially impacted by the
catastrophic event. The objective of this review is to estimate the ultimate
expected cost to settle all claims and administrative costs arising from
catastrophic events that have occurred as of the latest balance sheet date. We
initially set our claims reserves based on case reserves reported to us by
insureds and ceding companies, but which have not yet been paid. We then add to
these case reserves the costs for additional case reserves which represent our
estimates for claims reported to us which we believe may not be adequately
reserved. Our estimate of the anticipated cost of claims incurred but not yet
reported to us ("IBNR") is then determined by deducting paid losses, case
reserves and additional case reserves from our estimate of the ultimate expected
loss for an event. Under GAAP, we are not permitted to establish estimates for
catastrophe claims and claim expense reserves until an event occurs that gives
rise to a loss.


























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August 18, 2006
Page 13


                                    EXHIBIT C


Within our property catastrophe reinsurance business, we seek to review
principally all of our claims and claim expense reserves quarterly. Our
quarterly review procedures include identifying events that have occurred up to
the latest balance sheet date, determining our best estimate of the ultimate
expected cost to settle all claims and administrative costs associated with
those new events which have arisen during the reporting period, and reviewing
the ultimate expected losses to settle claims for previous events. As noted
above, because events from which claims arise under our property catastrophe
excess of loss reinsurance policies are typically prominent, public occurrences
such as hurricanes, earthquakes and other natural and man-made catastrophes,
these events are generally known shortly after they occur. Once an event has
occurred, we record our best estimate of the ultimate expected cost to settle
all claims arising from the event during the current reporting period. For
smaller catastrophes such as winter storms and localized severe weather events
such as windstorms and tornadoes, we review catastrophe bulletins published by
statistical reporting agencies to assist us in determining what events occurred
during the reporting period. We set our initial estimates of reserves for claims
and claim expenses for these smaller events based on a combination of our
historical market share for these types of losses and the estimate of the total
insured industry property losses as reported by statistical reporting agencies.
This approach supplements our approach for estimating losses for larger
catastrophes, which as discussed above, includes discussions with brokers and
ceding companies, reviewing individual contracts impacted by the event, and
modeling the loss in our REMS system. In addition, the quarterly review process
includes a review of the ultimate expected loss for each loss that has occurred
since the Company's inception. This process is judgmental in that it involves
reviewing changes in paid and reported losses each period and adjusting our
estimates of the ultimate expected losses for each event if there are changes
that are different from our previous expectations. If we determine that
adjustments to an earlier estimate are appropriate, such adjustments are
recorded in the quarter in which they are identified.
























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August 18, 2006
Page 14


                                    EXHIBIT D


Our reserving methodology for each line of business uses a loss reserving
process that calculates a point estimate for the Company's ultimate expected
losses. We do not calculate a range of estimates. We use this point estimate,
along with paid and reported claims data, to record our best estimate of
additional case reserves and IBNR in our financial statements.

Our claims and claim expense reserves are reviewed annually by an independent
actuarial firm. The actuarial firm performs this work for the purpose of issuing
an actuarial opinion on the reasonableness of the Company's claims and claim
expense reserves for each of the Company's insurance subsidiaries. The actuarial
opinions are required to meet various insurance regulatory requirements. The
actuarial firm discusses their conclusions with management and presents their
findings to the Audit Committee of the Board of Directors of the Company.
Although we do not explicitly rely on the work performed by the actuarial firm
for estimating our reserves for claims and claim expenses, we compare our
recorded claims and claim expense reserves to those estimated by the actuarial
firm to ensure our estimates are within the actuarial firm's reasonable range of
estimates. To date, our estimates of claims and claim expense reserves have been
within the actuarial firm's reasonable range of estimates.
























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August 18, 2006
Page 15


                                    EXHIBIT E



We announced in early 2005 that we would review the processes and assumptions
for establishing and evaluating our reserves during 2005. Starting in 2002, we
significantly expanded our specialty reinsurance and Individual Risk businesses
which resulted in significant growth in our reserves for claims and claim
expenses for these lines of business over the subsequent three years. When
establishing our initial reserves for these lines of business, we placed
significant reliance on industry data as we did not have the benefit of our own
historical experience. Prior to 2005, we started experiencing favorable
development on the run-off of our reserves. This favorable development was
principally due to our specialty reinsurance and Individual Risk businesses
performing better than historical industry averages and paid and reported claims
developing better than expected in our property catastrophe reinsurance
business. We elected to perform our reserve reviews in 2005 principally due to:
1) the growth in our businesses and reserves for claims and claim expenses; 2)
an increase in then-recent periods in favorable development in reserves for our
specialty reinsurance and Individual Risk businesses, which had performed more
favorably in what was effectively their first three years of operations than
historical industry data would have anticipated; 3) recent favorable development
with respect to our property catastrophe reinsurance reserves; and 4) a
determination to consider enhancements to our reserving processes and
assumptions.

We completed reviews of our property catastrophe reinsurance reserves, specialty
reinsurance reserves and Individual Risk reserves in the second, third and
fourth quarters of 2005, respectively. As a result of these reviews, we reduced
prior year reserves within our Reinsurance and Individual Risk segments by
$248.1 million and $1.1 million, respectively. Within our Reinsurance segment,
the decrease included a $118.2 million decrease in reserves for our property
catastrophe reinsurance business and a $129.9 million decrease in reserves for
our specialty reinsurance business. After adjusting for the impact of minority
interest, our 2005 net loss was reduced by $226.9 million as a result of these
reviews.

Within our Reinsurance segment, we experienced a decrease in our property
catastrophe reinsurance reserves for claims and claim expenses principally due
to re-estimating the ultimate expected cost for both small and large
catastrophes. This was due to a reassessment of our reserves for claims and
claim expenses in light of historical paid loss trends and reported loss
activity for these catastrophes. In coming to this conclusion, we reviewed
claims files, requested updated claims information from brokers, and developed
some new tools to help us assess trends in paid and reported losses. As a result
of this review, we determined that there were trends of paid and reported claims
for these catastrophes that were coming in less than originally expected and
therefore the ultimate expected losses for these catastrophes were decreased.

The review also included a reassessment of our actuarial techniques and
assumptions for our specialty reinsurance business. We considered whether or not
we should continue with the use of the Bornhuetter-Ferguson actuarial method in
reserving for our specialty reinsurance business






Securities and Exchange Commission
August 18, 2006
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or whether a different actuarial method might be more appropriate. As a result
of the review, we determined it was appropriate to continue with the use of the
Bornhuetter-Ferguson actuarial method. This method is appropriate for lines of
business, such as our specialty reinsurance business, where there is a lack of
historical claims experience. This method only uses initial loss ratio
expectations to the extent that losses are not paid or reported and it assumes
that past experience is not fully representative of the future. This method also
has the benefit of placing more weight on actual experience and less on expected
experience as the Company's reserves for claims and claim expenses age.

To enhance the reserving for our specialty reinsurance business, we further
segmented this business during the review with the aim of grouping risks into
more homogeneous categories which respond to the evolution of actual exposures.
This became possible as the volume of this business increased over the three
preceding years. This further segmentation required the selection of loss
reporting patterns to be applied to these new groups. We also updated our
assumptions for our original loss reporting patterns based on a combination of
new industry information and actual experience accumulated over the three
preceding years. The assumptions for the new loss reporting patterns were
applied to all prior underwriting years. In addition, we made explicit
allowances for commuted contracts whereas previously these were considered in
the overall reserving assumptions. We also reviewed substantially all of our
case reserves and additional case reserves. The result of the foregoing was a
decrease in our specialty reinsurance reserves for claims and claim expenses.

The reserve review for our Individual Risk business followed a similar process
to the specialty reinsurance review noted above. The changes within our
Individual Risk segment as a result of the reserve review were insignificant.