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    secletter040808.htm

    April 8, 2008

    VIA FACSIMILE AND
EDGAR

    Securities and Exchange Commission

    100 F Street, N.E.

    Washington, D.C.  20549

    Attn:   Jennifer Riegel, Esq.

                Staff
Attorney

Division of Corporate Finance

    Re:   Comments Letter dated March 21,
2008

    Dear Ms. Riegel:

    We are in receipt of
the Commission’s letter of March 31, 2008, commenting on the Form 10-K
filed by Old Republic International Corporation (the “Company”) for the year
ended December 31, 2007 (File No. 001-10607), and offer the following
in response to the correspondingly numbered comments:

    1. At
December 31, 2007, our operating subsidiaries held slightly more than $4 billion
in standby letters of credit as collateral security for various insurance and
reinsurance obligations that were either due to us or expected to become due to
us.  While the letters of credit have been issued by over 300
different institutions, most of them U.S. domiciled banks, a relatively small
number of these banks have issued letters of credit aggregating over
$100 million.  At the same time, our title insurance subsidiaries
have banking relationships with approximately 50 banks in which moneys are held
in escrow accounts, pending the closing of real estate transactions in which our
subsidiaries serve as the escrow agents.  During 2007, the balances in
these escrow accounts at their highest points aggregated $93.7 million, though
only one held more than $10 million.

    Jennifer Riegel, Esq.

    Securities and Exchange Commission

    April 8, 2008

    Page 2

    At year end 2007, each of the following institutions had issued us
letters of credit exceeding $100 million and also served as a depository
for escrow account funds:  Bank of America, N.A., Comerica Bank,
HSBC Bank USA, N.A., JPMorgan Chase Bank, SunTrust Bank, Wachovia Bank,
N.A. and Wells Fargo Bank, N.A.

    The risk referred to in the discussion on Page 18 of our Form 10-K is
that one or more of these institutions could become insolvent and unable to
honor their letters of credit if we ever had to draw on them and/or their
insolvency could jeopardize the availability of escrow account funds that we are
responsible for disbursing.  Given the amount of credit issued by
them, the result could have an adverse material effect on the operating results
and financial condition of our subsidiaries and perhaps the Company
itself.  Apart from insolvency, there is also a risk that the issuing
banks might dishonor the draws or default in paying our drafts under letters of
credit.  While the risk is not high (and, in the case of the letters
of credit, there would first have to be a default or insolvency of one or more
significant insureds or reinsurers, or the simultaneous defaults or insolvencies
of a number of the lesser-sized insureds or reinsurers, giving us cause to draw
on the letters of credit, followed by the insolvency, wrongful dishonor or
default of the issuing bank or banks) it is a potential risk of sufficient
concern to us that we actively attempt to manage it.  We annually
establish a list of institutions that we deem acceptable and establish
individual limits on the amount of credit we will accept from each institution
or the amount of escrowed funds we are willing to deposit with each based upon
their size and credit ratings, among other factors.

    However, the letters of credit and escrow deposit accounts are not, in
our view, market risk sensitive instruments within the meaning of Item 305 of
Regulation S-K.  There is no trading in these instruments; there is no
interest rate or currency exposure; there is nothing variable about the amount
of credit established or dollars deposited and held in escrow.  The
risk is one of insolvency and, to a lesser extent, the failure or refusal of a
financial institution to perform as required when called
upon.  Between the extremes of a perfect case scenario and a worse
case scenario, there is no way, in our opinion, to model the risk or quantify
it.

        Jennifer Riegel, Esq.

        Securities and Exchange Commission

        April 8, 2008

        Page 3

    Accordingly, while we do not think this risk lends itself to Item 305
of Regulation S-K, we will expand our discussion of the Financial Institutions
Risk in future Forms 10-K and any other filings requiring a discussing of Item
503(c), Regulation S-K risk factors to disclose the names of those institutions
from which we hold $100 million or more in letters of credit and which also
serve as escrow account depositories.

    2. Karl
Mueller is both our Chief Financial Officer and our principal accounting officer
and, although the latter is not part of his formal title, it will be added below
his signature line in the future.

    We hereby acknowledge that the Company is responsible for the adequacy
and accuracy of the disclosure in the filing; that Staff comments or changes to
disclosure in response to Staff comments do not foreclose the Commission from
taking any action with respect to the filing; and that Company may not assert
Staff comments as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

    Very truly yours,

    /s/ Spencer LeRoy

    Spencer LeRoy

    SL/cbf

    cc:  K. Mueller

           A. Zucaro