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May 29, 2024
Theodore R. Stalick
Senior Vice President and Chief Financial Officer
Mercury General Corporation
4884 Wilshire Boulevard
Los Angeles, California 90010
Re:Mercury General Corporation
Form 10-K for the Fiscal Year Ended December 31, 2023
File No. 001-12257
Dear Theodore R. Stalick:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2023
Notes to Consolidated Financial Statements
Note 12. Loss and Loss Adjustment Expense Reserves, page 85
1.Please address the following regarding your automobile insurance loss development and
payment tables:
•Tell us whether these tables include both your personal and commercial automobile
lines and represent to us that you will revise your disclosure in future filings to
clarify. Otherwise, tell us where you make this disclosure in your filing.
•Tell us your consideration for disaggregating bodily injury from material damage
coverage in your tables. In this regard, we note that the majority of your 2023 direct
written premium is private passenger automobile lines and we further note your
disclosure in the last paragraph on page 65 that time can be a critical part of reserving
determinations since the longer the span between the loss event and the settlement of
the claim, the more variable the ultimate settlement amount could be and that short-
tail claims, such as property damage claims, tend to be more reasonably predictable
than long-tail claims, such as those involving bodily injury coverages. In addition, we

 FirstName LastNameTheodore R. Stalick
 Comapany NameMercury General Corporation
 May 29, 2024 Page 2
 FirstName LastNameTheodore R. Stalick
Mercury General Corporation
May 29, 2024
Page 2
note the requirement in ASC 944-40-50-4H to not aggregate items that have
significantly different characteristics. In your response, provide us the information
that would be provided in separate tables for automobile bodily injury coverage and
automobile material damages coverage, if available. If not available, tell us why it is
not available given your ability to identify the percentage of total reserves attributed
to bodily injury versus material damages coverages as disclosed on page 37.
2.We note that in addition to your automobile insurance loss development and
payment tables you provide separate tables for your homeowners insurance line. Please
tell us why you do not provide tables for any of your other insurance lines and reference
for us the authoritative literature you rely upon to support your position. In this regard, we
note that your tables present:
•About $59.1 million in favorable development ($34.5 million for automobile and
$24.6 million for homeowners) in 2023 while your reserve rollforward on page 85
depicts consolidated favorable development of only $35.9 million. Although you
disclose on page 85 that you experienced private passenger automobile and
homeowner lines losses partially offset by unfavorable development in the
commercial property line, the aggregate $23.2 million unfavorable difference
between the total presented in the tables and the reserve rollforward appears
significant to the overall $175.4 million net reserve at January 1, 2023 for all other
short-duration lines and on the surface does not appear insignificant to an
understanding of your business as contemplated in ASC 944-40-50-4H.
•About $81.8 million in unfavorable development ($80.3 million for automobile and
$1.5 million for homeowners) in 2022 while your reserve rollforward on page 85
depicts consolidated unfavorable development of only $47.3 million. Although you
disclose on page 85 that the $47.3 million unfavorable development primarily relates
to the automobile line, the aggregate $34.5 million favorable difference between the
total presented in the tables and the reserve rollforward appears significant to the
overall $148.4 million net reserve at January 1, 2022 for all other short-duration lines
and on the surface does not appear insignificant to an understanding of your business
as contemplated in ASC 944-40-50-4H. In addition, tell us your consideration for
separately disclosing the existence and cause of the apparent $34.5 million in
favorable development, and tell us the breakout of the $47.3 million of unfavorable
development between the private passenger and commercial automobile
components.
            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.

 FirstName LastNameTheodore R. Stalick
 Comapany NameMercury General Corporation
 May 29, 2024 Page 3
 FirstName LastName
Theodore R. Stalick
Mercury General Corporation
May 29, 2024
Page 3
            Please contact Mark Brunhofer at 202-551-3638 or Bonnie Baynes at 202-551-4924 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Crypto Assets