SecProbe.io

April 4, 2013

Via E-mail
Mr. Paul Rivett
Vice President, Operations
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, 2012
  Filed March 8, 2013
File No. 001 -31556

Dear  Mr. Rivett :

We have reviewed your filing and have the following comments.  In our
comments, we ask you to provide us with information so we may better understand your
disclosure.

Please respond to this letter within 10 business days by providing the requested
information or by advising us when you will provide the requested response.   If you do
not believe a comment app lies to your facts and circumstances, please tell us why in your
response.  Please furnish us a letter on EDGAR under the form type label CORRESP that
keys your responses to our comments.

After reviewing the information provided, we may raise additional  comments
and/or request that you amend your filing.

Exhibit 1:  Annual Information Form
Audit Committee, page 14

1. In the last sentence on page 14 you indicate that your auditor provides you claims
handling services.  Please tell us the nature of these s ervices and how they are not
precluded services under Item 2 -01(c)(4)  of Regulation S -X, addressing each type
of service identified in the reference d Item.

Mr. Paul Rivett
Fairfax Financial Holdings Limited
April 4, 2013
Page 2

 Exhibit 2:  Audited Consolidated Financial Statements

Consolidated Statements of Earnings, page  28

2. You present net premiums earned on the face of your statements of earnings.  You
also present net losses on claims, albeit as a subtotal of gross losses on claims less
ceded losses.  Please tell us why th ese net p resentation s are not precluded by
paragraph 14(d)(ii) of IFRS 4 .

Notes to Consolidated Financial Statements

3. Summary of Significant Accounting Policies
Investments in associates, page 35

3. In the first paragraph on page 36 you indicate that the difference between your
end of the reporting period and that of your associates is generally no more than
three months.  As paragraph 25 of IAS 28 limits the maximum lag to three
months, please tell us which associates have a lag of greater than three months
and for each such associate tell  us the following:
 the carrying value of your investment;
 your share of earnings in 2012 and 2011;
 the lag period you use; and
 an explanation as to why you cannot obtain financial statements within three
months of your period end.

5. Cash and Investments,  page 50

4. Please explain to us where the pledged assets in the first table on page 51 and
those pledged to Lloyd’s, totaling $4.0 billion at December 31, 2012, are
classified on your consolidated balance sheet.  Provide us proposed disclosure to
be includ ed in future filings that clarifies where these assets are recorded.
Separately explain to us why these pledged assets are not specifically segregated
on your balance sheet like the assets pledged for short sale and derivative
obligations and reference fo r us the authoritative literature you rely upon to
support your presentation.

9. Reinsurance, page 63

5. You state that in the past a significant amount of adverse reserve development has
been ceded under your reinsurance treaties and that if further adve rse reserve
development were to occur, little if any could be ceded to reinsurers  in future
periods.  Please provide us proposed MD&A disclosure to be included in future
filings  that describes this uncertainty regarding adverse development  and

Mr. Paul Rivett
Fairfax Financial Holdings Limited
April 4, 2013
Page 3

 quantifies t he expected impact of o n your future  financial position and operating
results .

18. Income Taxes, page 75

6. Please provide us proposed disclosure to be included i n future filings that
describes changes in your  domestic tax rate and other jurisdiction tax rates and
explains factors underlying changes  in the mix of profits/losses earned in the
different jurisdictions for each period presented.   Refer to paragraphs 81(d) and
85 in IAS 12.

7. Please provide us proposed disclosure to be included in future filings that
describes t he factors underlying changes in the captions in your reconciliations of
income tax calculated at the statutory and effective tax rates, part icularly changes
in the  “Tax rate differential on income and losses incurred outs ide Canada” and
“Change in unrec orded tax benefit of losses.”  Refer to paragraph 81 of IAS 12.

20. Contingencies and Commitments, page 78

8. You assert that the financial effect of uninsured litigation loss exposure on your
financial position is not material.  Please provide us proposed disclosure to be
included in future filings under paragraph 86 of IAS 37 that discusses each known
contingenc y that could have a material impact on your results of operations or
cash flows in any period.  In this regard, it appears that the requirement to
disclose an estimate of a contingency’s financial effect is not limited to its
potential impact on the balanc e sheet.

Exhibit 3:  Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Sources of Net Earnings, page 120

9. Please provide an analysis of income tax expense , including a description of the
factors underlying changes in  this expense  for each period pre sented, as proposed
disclosure to  be included in future filings.

Net Earnings by Reporting Segment, page 123

10. Please provide us proposed MD&A disclosure to be included in future filings that
quantifies the impact of your  reinsurance activities on your underwriting profit
(loss) for each segment and explains the factors underlying changes in this impact
for each period presented.

Mr. Paul Rivett
Fairfax Financial Holdings Limited
April 4, 2013
Page 4

 We urge all persons who are responsible for the accuracy and adequacy of the
disclosu re in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchange Act rules require.   Since the company
and its management are in possession of all facts relating to a company’s disclosu re, they
are responsible for the accuracy and adequacy of the disclosures they have made.

  In responding to our comments, please provide a written statement from the
company acknowledging that:

 the company is responsible for the adequacy and accuracy of the disclosure in the
filing;
 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
 the company may not assert staff comments as a defense in any proc eeding
initiated by the Commission or any person under the federal securities laws of the
United States.

Please contact Frank Wyman, Staff Accountant, at (202) 551 -3660 or Mark
Brunhofer, Senior Staff Accountant , at (202) 551 -3638  if you have any question s
regarding the comments. In this regard, do not hesitate to contact me at (202) 551 -3679.

Sincerely,

 /s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief
Accountant