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CRAWFORD & COMPANY (Registrant)
5620 Glenridge Dr. NE
Atlanta, GA 30342

October 28, 2005

VIA EDGAR AND FACSIMILE

Mr. Jim B. Rosenberg, Senior Assistant Chief Accountant
Mr. Oscar M. Young, Jr., Senior Accountant
Division of Corporate Finance
United States Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

Re: CRAWFORD & COMPANY
    FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2004
    FILED MARCH 15, 2005
    FILE NO. 001-10356

Dear Mr. Rosenberg and Mr. Young:

This letter sets forth the responses of Crawford & Company (the "Company" or
"we" or "our") to the comments of the staff of the U.S. Securities and Exchange
Commission (the "Commission") contained in your letter dated September 26, 2005
("Comment Letter") pertaining to our Form 10-K for the year ended December 31,
2004. We have repeated below each of the staff's comments from the Comment
Letter, with the Company's response to each comment immediately following.

EXHIBIT 13.1 - PORTIONS OF THE REGISTRANT'S ANNUAL REPORT

MANAGEMENT'S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF
OPERATIONS

RESULTS OF OPERATIONS

1.   Please tell us how your presentation of "operating earnings," which
     excludes net corporate interest and income taxes (apparently, recurring
     items), complies with Item 10(e) of Regulation S-K. In doing so, please
     address Answers 8 and 21 of the "Frequently Asked Questions Regarding the
     Use of Non-GAAP Financial Measures." In this regard, while reporting
     consolidated "operating earnings" may be necessary to provide the
     reconciliation of segment "operating earnings" required by paragraph 32(b)
     of SFAS 131, it does not appear appropriate to present and discuss
     consolidated "operating earnings" as a measure that would be useful to
     investors in evaluating your consolidated results of operations.
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Mr. Jim B. Rosenberg and Mr. Oscar M. Young, Jr.
October 28, 2005
Page 2 of 17

     COMPANY'S RESPONSE:

     We agree that net corporate interest expense and income tax expense are
     recurring items for our company. However, we also recognize that Earnings
     Before Interest and Taxes (EBIT) is a common non-GAAP financial measure
     used by many public companies. Item 10(e)(1)ii(A) of Regulation S-K
     specifically permits EBIT as a non-GAAP liquidity measure because of its
     wide and recognized existing use. While we do not specifically describe our
     operating earnings as a measure of liquidity, we believe that EBIT is
     commonly used as a measure of financial performance as well. As discussed
     in Answer 15 to the "Frequently Asked Questions Regarding the Use of
     Non-GAAP Financial Measures," we provide a reconciliation between our
     operating earnings and GAAP net income.

     Answer 8 to the "Frequently Asked Questions Regarding the Use of Non-GAAP
     Financial Measures" contains five items that need disclosure in order for a
     non-GAAP measure to not be misleading:

     1)   the manner in which management uses the non-GAAP measure to conduct or
          evaluate its business

     In the section of our Management's Discussion and Analysis of Financial
     Condition and Results of Operations ("MD&A") preceding the required
     reconciliation between operating earnings (non-GAAP) and net income on a
     GAAP basis, we will enhance the initial references to operating earnings as
     follows: "Operating Earnings is a key performance measure our senior
     management and chief decision maker use to evaluate the operating
     performance of our business, set incentive compensation targets, and make
     resource allocation decisions. We believe this measure is useful to
     investors in that it allows them to evaluate our operating performance
     using the same criteria our management uses."

     2)   the economic substance behind management's decision to use such a
          measure

     We do not believe net income would be as useful a measure to investors in
     assessing our operating performance. In our MD&A, we will add the following
     disclosure: "Net corporate interest expense results from capital structure
     decisions made by us, and income taxes are based on statutory rates in
     effect in each of the locations where we provide services and vary
     throughout the world. Neither of these costs relates directly to the
     performance of our services and are
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Mr. Jim B. Rosenberg and Mr. Oscar M. Young, Jr.
October 28, 2005
Page 3 of 17

     therefore excluded in order to accurately assess the results of our
     operating activities on a consistent basis. Special credits and charges
     represent nonrecurring events that are not considered part of our operating
     earnings since they historically have not impacted our performance and are
     not expected to impact our performance within the next two years."

     3)   the material limitations associated with the use of the non-GAAP
          financial measures as compared to the use of the most directly
          comparable GAAP financial measure

     We know of no material limitations associated with the use of operating
     earnings as a key financial measure. We provide separate MD&A for the items
     excluded from our operating earnings so that we can provide a focused
     discussion on our core operating performance. The special credits and
     charges have caused fluctuations in our GAAP net income that are not
     reflective of our continuing, core operations. We believe it would be
     materially misleading to base MD&A on GAAP net income because it would not
     properly identify and isolate these non-operating items from our core
     operating performance. For instance, with the exception of 2003, net income
     under GAAP for the last five years (2000 through 2004) has shown little
     change. However, our operating earnings have declined steadily with the
     slight exception in 2004. MD&A focused on our operating earnings provides a
     clearer understanding of the declining profitability within our core
     business operations.

     4)   the manner in which management compensates for these limitations when
          using the non-GAAP financial measure

     In our MD&A, we explain that our consolidated operations are discussed and
     analyzed by separately discussing operating earnings from the components of
     net income that are not considered part of operating earnings. However, our
     MD&A does effectively discuss and analyze all components of our GAAP net
     income.

     5)   the substantive reasons why management believes the non-GAAP financial
          measure provides useful information to investors

     In addition to our answers to questions number 2 and 3 above, in our MD&A
     we will clarify the presentation so that the reader better understands how
     we evaluate our consolidated operations by segregating our operating
     earnings from the other components of consolidated net income. Discussion
     of our
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Mr. Jim B. Rosenberg and Mr. Oscar M. Young, Jr.
October 28, 2005
Page 4 of 17

     operating earnings is most informative by addressing the operating earnings
     of our two reportable segments separately since our operating earnings are
     attributed to these two segments. The components of our consolidated net
     income not included in operating earnings (net corporate interest expense,
     income taxes, special charges/credits) are addressed separately.

     In order to better organize the overall presentation of our discussion and
     analysis of consolidated operations in future filings, we intend to move
     the MD&A for "Special Credits and Charges, Net Corporate Interest Expense,
     and Income Taxes" to the section of the MD&A immediately preceding the
     discussion and analysis of our two segments' operating results. It should
     be clearer to the reader that we have addressed our consolidated operations
     using an appropriately organized discussion and analysis. We will also
     explain more clearly why management removes net corporate interest expense
     and income taxes from operating earnings. We believe this enhanced MD&A
     will better comply with Item 10(e)(1)(i)(C) of Regulation S-K and with
     Answers 8 and 21 to the Frequently Asked Questions Regarding the Use of
     Non-GAAP Financial Measures, particularly the "burden of proof"
     requirement. We will make
     these enhancements to our MD&A beginning with our Quarterly Report on Form
     10-Q for the quarterly period ended September 30, 2005. (See Attachment A
     to this letter for our planned description and placement of these MD&A
     enhancements).

2.   We noted that you disclosed "revenue" that does not agree to your
     statements of operations and that your discussion of revenue was based on
     "revenues before reimbursements." While we note that you discuss
     reimbursements elsewhere, it is unclear why you do not provide a separate
     discussion of revenue that addresses all amounts included in "total
     revenues" on your statements of operations. As such, please tell us how
     your discussion of revenue complies with Item 303(a)(3)(i) of Regulation
     S-K or provide us a discussion that would comply with it.

     COMPANY'S RESPONSE:

     In the normal course of conducting our business, we often directly pay for
     certain out-of-pocket expenses that will later be reimbursed to us by our
     clients under the terms of our agreements with these clients. As such, we
     do not "earn" such reimbursements since we consider them to be "pass
     through"
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Mr. Jim B. Rosenberg and Mr. Oscar M. Young, Jr.
October 28, 2005
Page 5 of 17

     expenses without mark-up. Prior to 2002, we did not include reimbursed
     out-of-pocket expenses in our consolidated revenues or expenses.

     However, in November 2001, EITF 01-14 "Income Statement Characterization of
     Reimbursements Received for Out-of-Pocket Expenses Incurred" was issued.
     Under certain circumstances, EITF 01-14 requires reimbursed out-of-pocket
     expenses to be reported as revenues and expenses in the statement of
     income. Our consolidated financial statements reflect our adoption of EITF
     01-14. We report these reimbursed expenses as a component of revenue and as
     a separate component of costs and expenses. These amounts offset one
     another in our Consolidated Statements of Income with no net impact to our
     net income.

     However, for purposes of MD&A we do not believe it would be informative to
     discuss and analyze our operations by "grossing up" our earned revenues for
     these "pass through" reimbursements. We note in numerous places within our
     MD&A that "revenue amounts exclude reimbursements for out-of-pocket
     expenses" and "expense amounts exclude reimbursed out-of-pocket expenses."
     Item 303(a)(3)(i) of Regulation S-K states in part, "...describe any other
     significant components of revenues or expenses that, in the registrant's
     judgment, should be described in order to understand the registrant's
     results of operations." Since these expense reimbursements are passed
     through and have no impact on our net income or operating earnings, we do
     not believe a separate discussion of "total revenue" is necessary in order
     to understand our operating results. We believe that we are in compliance
     with Regulation S-K.

     However, we will amend our future MD&A to ensure that the discussions and
     analysis of revenues and expenses inform the reader when reimbursed
     expenses are excluded from a specific discussion or analysis of revenues or
     expenses. In addition, we will clarify the disclosure in our MD&A relating
     to revenues by renaming the existing "Revenues" caption "Revenues before
     Reimbursements" and adding a new discussion covering "Reimbursements
     included in total revenues." On the table appearing on page 20 of MD&A in
     our Annual Report on Form 10-K for the year ended December 31, 2004, we
     will add a reconciliation for the 2005 table that reconciles "Revenues
     before Reimbursements" to total Consolidated Revenues and a similar
     reconciliation for "Expenses Other than Compensation and Fringe Benefits."
     We will make these enhancements to our MD&A beginning with our Quarterly
     Report on Form 10-Q for the quarterly period ended September 30, 2005. (See
     Attachment A to this letter for these planned MD&A enhancements).
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Mr. Jim B. Rosenberg and Mr. Oscar M. Young, Jr.
October 28, 2005
Page 6 of 17

CONSOLIDATED FINANCIAL STATEMENTS

CONSOLIDATED STATEMENTS OF SHAREHOLDERS' INVESTMENT

3.   Please tell us how your inclusion of tax benefit from exercise of stock
     options in comprehensive income complies with SFAS 130, as paragraphs 8 and
     9 appear to indicate that investments by owners should not be included.

     COMPANY'S RESPONSE:

     We agree with your comments and references to SFAS 130, "Reporting
     Comprehensive Income," paragraphs 8 and 9. These tax benefits from
     exercises of stock options originated from equity transactions with owners
     of the Company's common stock, and as such should be reported as activity
     within Additional Paid-In Capital in our Consolidated Statements of
     Share-holders' Investment and Consolidated Balance Sheets. This represents
     only a classification issue between Other Comprehensive Income (Loss) and
     Additional Paid-In Capital within shareholders' investment, and has no net
     impact on our consolidated shareholders' investment, assets, liabilities,
     revenues, expenses, net income or earnings per share at December 31, 2004,
     or in the financial statements of any period presented in our Annual Report
     on Form 10-K for the year ended December 31, 2004.

     We plan to adopt SFAS 154, "Accounting Changes and Error Corrections," at
     the beginning of 2006. However, we understand that SFAS 154 carries forward
     the existing provisions of APB Opinion No. 20, "Accounting Changes," SFAS
     3, "Reporting Accounting Changes in Interim Financial Statements," and
     paragraph 26 of APB Opinion No. 9, "Reporting the Results of Operations,"
     that are related to the reporting and disclosure of a correction of an
     error. We believe the reclassification needed in our Consolidated
     Statements of Shareholders' Investment and Consolidated Balance Sheets
     meets the definition of an error since it is a mistake in the application
     of an accounting principle (paragraphs 16 and 17 of APB 25, "Accounting for
     Stock Issued to Employees," as amended by paragraph 288(g) of SFAS 109).

     Since this reclassification has no impact on the current or any prior
     periods' net income or retained earnings, only the Consolidated Statements
     of Shareholders' Investment and Consolidated Balance Sheets and related
     footnote are impacted.

     The reclassification of $4.165 million represents only 2.1%, 2.4%, and 2.6%
     of the Company's consolidated shareholders' investment at December 31,
     2004, 2003, and 2002, respectively. As noted, this misclassification has no
     net impact
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Mr. Jim B. Rosenberg and Mr. Oscar M. Young, Jr.
October 28, 2005
Page 7 of 17

     on shareholders' investment. Qualitatively, we do not believe the impact of
     the error on our 2002 consolidated comprehensive loss, when considered with
     the offsetting impact in our additional paid-in capital, would influence a
     reasonable shareholder or investor in deciding whether to purchase or sell
     the Company's securities or has significantly altered the total mix of
     information available. In addition, security analyst reports covering the