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                                                                                                September 9, 2009

Mr. Greg Taylor
Vice President and Chief Financial Officer
Fairfax Financial Holdings Limited
95 Wellington Street West, Suite 800
Toronto, Ontario Canada M5J 2N7

Re: Fairfax Financial Holdings Limited
 Form 40-F for the Fiscal Year Ended December 31, 2008
Filed March 6, 2009 File No. 1-31556
 Dear Mr. Taylor:

We have reviewed your June 25, 2009 res ponse to our June 11, 2009 letter and
have the following comments.  In our comments, we ask you to provide us with information to better understand your disc losure.  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 f iling, in which you intend to fi rst include it.  If you do not
believe that revised disclosure  is necessary, explain the reason in your response.  After
reviewing the information provided, we may raise additional comments and/or request
that you amend your filing.

Form 40-F for Fiscal Year Ended December 31, 2008

18. Financial Risk Management, page 60

1.     Please refer to prior comments three, four and six. Please revise your disclosure
to explain how you revised the financia l objectives of your  hedging programs
given market conditions and the impact of  your sales and close out transactions
in 2008 in order to effectively manage the Company’s future credit risk and
market risk.

Mr. Greg Taylor
Fairfax Financial Holdings Limited   September 9, 2009 Page 2
 Exhibit 3

Management’s Discussion and Analysis of Fi nancial Condition and Results of Operations
 Components of Net Earnings

Net gains on investments, page 111

2.     Please refer to prior comments eight and nine. We acknowledge the
information provided in your respon ses, particularly how you employ
derivative instruments to mitigate financ ial risks arising principally from your
investment holdings and balances recoverable from reinsurers. The impact of
these derivative instruments and related hedged items, as presented in Notes 3 and 4 of your financial statements, appears to have been summarized in Appendix 1 of your response. Please disc lose this summarized information in
future filings along with an explanati on quantifying the eff ects that the key
factors of your hedging programs had on the Company’s financial position,
results of operations and cash flows  as  of and for each period presented.

3.     You assert in your responses to comments 3, 4 and 7 that it is not possible to
“definitively quantify” how your deri vative instruments and related hedged
items are expected to affect your future  financial position, results of operations
and cash flows. Please revise your MD &A to describe and quantify the
“reasonably likely” future impact of  your hedging programs. Otherwise,
disclose the risks, data limitations, mark et uncertainties or other factors that
prohibit you from providing his information.

4.    Please refer to prior comment 11. We ac knowledge the information provided in
your response. Please confirm to us that you will incorporate this information in future filings.

*    *    *    *

Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that  keys your responses to our
comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please furnish your letter on EDGAR under the form type label CORRESP.

Please contact Frank Wyman, Staff A ccountant, at (202) 551-3660 or Don
Abbott, Senior Staff Accountant, at (202) 551-3608, if you have any questions regarding
the comments. In this regard, do not he sitate to contact me at (202) 551-3679.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant