SecProbe.io

Mail Stop 6010 Via Facsimile and U.S. Mail
                                                                                                December 14, 2007

Mr. V. Prem Watsa Chairman and Chief Executive Officer Fairfax Financial Holdings Limited  95 Wellington Street West, Suite 800 Toronto, Ontario Canada M5J2N7
Re:      Fairfax Financial Holdings Limited             Form 40-F for fiscal year ended December 31, 2006
            File No. 1-31556
Dear Mr. Watsa:

We have reviewed your September 28, 2007 response to our September 19, 2007
letter and have the following comments. In ou r comments, we ask you to provide us with
information so we may better understand your  disclosure.  After reviewing this
information, we may raise additional comments.

Form 40-F for fiscal year  ended December 31, 2006

Off-Balance Sheet Arrangements
1. We acknowledge your response to comment one, particularly your statement that
the disclosures in Notes 4, 13 and 15 “relat e to arrangements that are more aptly
described as contingencies and not off- balance sheet arrangements.”  In your
response, you describe only two off-bala nce sheet arrangements, the pledge of
certain securities on behalf  of Advent and the obligation to assume loans to
officers and directors by Ca nadian banks. However, you appear to have engaged
in other off-balance sheet arrangements,  such as the $247.7 million pledge in
support of Syndicate 1218’s capacity at  Lloyd’s and reinsu rance-to-close
commitments between RiverStone Insurance UK, Lloyd’s of London Syndicate
3500 and Kingsmead syndicates 271 and 506.  Please expand your disclosure to
cover all arrangements with Lloyd’s s yndicates or explain your basis for
concluding that these activities did not constitute off-ba lance sheet arrangements.
Provide a quantification of the contractual oblig ations of Syndicate 3500,
including those related to Kingsmead  syndicates 271 and 506.  Please provide

Mr. V. Prem Watsa
Fairfax Financial Holdings Limited December 14, 2007 Page 2
 separate disclosure that  clearly identifies all of your off-balance sheet
arrangements in accordance with General Instruction B (11).

Exhibit 2 - Consolidated  Financial Statements

Notes to Consolidated Financial Statements
 Note 20. US GAAP Reconciliation, page 52

2. Please refer to prior comment four. Your res ponse appears to indicate that cost of
reinsurance is equivalent to ceded premiu ms as disclosed in Note 7.  However,
you also discuss ceded claims and state th at “the preceding analysis ignores the
impact of reinsurance commission and ba d debt expense.” Please provide a
clearer and more complete explanation and quantification of how you determine
cost of reinsurance and the effect of ceded reinsurance tr ansactions on your
operations for each period presented, as required in paragraph 27 of SFAS 113.

*    *    *    *

Please respond to these comments within  10 business days or tell us when you
will provide us with a respons e.  Your letter should key your responses to our comments.
Detailed cover letters greatly facilitate our review.  Please furnish your letter on EDGAR
under the form type label CORRESP.

You may contact Frank Wyman, St aff Accountant, at 202-551-3660  or Don
Abbott, Senior Staff Accountant, at 202- 551-3608, if you have questions regarding the
comments.  In this regard, do not hes itate to contact me, at (202) 551-3679.

       S i n c e r e l y ,            J i m  B .  R o s e n b e r g
      Senior Assistant Chief Accountant