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Mail Stop 6010 Via Facsimile and U.S. Mail
                                                                                                February 12, 2008
 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 December 2 0, 2007 response to our December 14, 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.  Where a comment requests
you to revise disclosure, the information you provide should show us what the revised disclosure will look like and identify the fili ng in which you intend to first include it.  If
you do not believe that revised disclosure is necessary, explain the reason in your
response.  After reviewing the informati on provided, we may raise additional comments
and/or request that you amend your filing.

Exhibit 2 - Consolidated  Financial Statements

Notes to Consolidated Financial Statements

Note 20. US GAAP Reconciliation, page 52

1. We have reviewed your response to pr ior comment two.  It is difficult to
determine the impact of reinsurance from  the proposed narrative disclosure for
Note 7.  We suggest that this proposed disc losure be revised to show the effect of
ceded reinsurance transac tions by including a presentation similar to the first
tabular presentation in your response to  comment two.  Also, please provide
revised disclosure to be included in MD &A that quantifies th e effect of ceded
reinsurance transactions on each year presen ted in your consolidated statements of
earnings and cash flows and that explai ns the reasons for period-to-period

Mr. V. Prem Watsa
Fairfax Financial Holdings Limited February 12, 2008 Page 2
 fluctuations.  The explanations of the fluctuations should cover each component
included in the above tabular presentation.
2. Please provide revised disclosure to be included in Note 2 Summary of Significant Accounting Policies – Reinsu rance that describes your accounting
policies for ceded reinsu rance, including your policies for each component
included in the above tabular presenta tion.  We would presume that these
accounting policies comply with U. S. GAAP  other than as disclosed in Note 20.

*    *    *    *

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