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CORRESP
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CORRESP

 April 18, 2013

 BY EDGAR

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street,
NE

 Washington, D.C. 20549

Attention:
Mr. Jim B. Rosenberg, Senior Assistant Chief Accountant

Mr. Mark Brunhofer, Senior Staff Accountant

Mr. Frank Wyman, Staff Accountant

Re:
Fairfax Financial Holdings Limited (“Fairfax”)

 Form 40-F for the Fiscal Year Ended December 31, 2012

 Filed
March 8, 2013

 File No. 001-31556

 Dear Sirs/Mesdames:

 We hereby acknowledge receipt of the comment letter dated April 4, 2013
(the “Comment Letter”) from the staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) concerning the above captioned Form 40-F (the “Form
40-F”). We submit this letter in response to the Comment Letter. For ease of reference, we have reproduced the text of the comments in bold-faced type below, followed by Fairfax’s responses. Page number references herein refer to the page
numbers of the Fairfax 2012 Annual Report appearing as Exhibits 2 and 3 of the Form 40-F, unless otherwise noted. Terms used but not defined herein have the meanings set forth in the Form 40-F. Fairfax (sometimes referred to herein as “the
company”) intends to include the revised disclosure as contemplated in this letter with respect to its reports on Form 40-F and Form 6-K, as applicable, beginning with the company’s Interim Report filed on Form 6-K for the period ending
March 31, 2013 and its Annual Report filed on Form 40-F for the fiscal year ending December 31, 2013. References to “the consolidated financial statements” means the company’s consolidated financial statements for the year
ended December 31, 2012 included as Exhibit 2 of the Form 40-F. References to “the MD&A” means the Management’s Discussion and Analysis of Financial Condition and Results of Operations for the year ended December 31,
2012 included as Exhibit 3 of the Form 40-F.

 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 services 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 referenced Item.

 Company’s Response

 The reference to “claims handling services” in the
description of “All other fees” was a typographical error. No such services were provided by PricewaterhouseCoopers LLP (“PwC”), the company’s auditor, in the past several years, including the past two fiscal years and this
was confirmed with PwC. All services provided by PwC in 2012 and 2011 were not precluded services under Item 2-01(c)(4) of Regulation S-X.

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 these net presentations are not precluded by paragraph 14(d)(ii) of IFRS 4.

Company’s Response

 The company
acknowledges the guidance in paragraph 14(d)(ii) of IFRS 4 which states that “an insurer shall not offset income or expense from reinsurance contracts against the expense or income from the related insurance contracts.” In determining the
appropriate IFRS presentation of revenue in its consolidated statement of earnings, the company noted that neither IFRS 4 Insurance Contracts nor IAS 18 Revenue specifically define what constitutes revenue from insurance operations and
that several revenue recognition models appeared acceptable based on IFRS 4 paragraph IG25 (reproduced in Appendix A). As described in Note 2 (Basis of Presentation) to the 2012 Annual Report, the company’s policy in these situations is to look
to the hierarchy of guidance in IAS 8 Accounting Policies, Changes in Accounting Estimate and Errors and to applicable guidance under US GAAP.

 FASB Codification paragraph 944-225-S99 under US GAAP contains the following SEC guidance:

 S99-1 The following is the text of Regulation S-X Rule 7-04, Income Statements.

 The purpose of this rule is to indicate the various items which, if applicable, should appear on the face of the income statements and in the notes thereto filed for persons to whom this article pertains.
(See 210.4–01(a).)

 2

 1. Premiums. Include premiums from reinsurance assumed and deduct premiums on reinsurance
ceded. Where applicable, the amounts included in this caption should represent premiums earned.

 The above guidance indicates that under
US GAAP, revenue for an insurance company would be comprised of net premiums earned. The company considers this definition of revenue to be acceptable under IFRS without contravening paragraph 14(d)(ii) of IFRS 4 because the company viewed net
premiums earned as the most relevant measure of revenue; hence ceded premiums constituted contra revenue rather than an expense. The Implementation Guidance to IFRS 4 paragraph IG25 (reproduced in Appendix A) further supports this view by permitting
variation in practice in respect of the disclosure of revenue and expenses of an insurer.

 Finally, the company believes its method of
presentation to be the most useful to readers of the consolidated financial statements in accordance with the IFRS Conceptual Framework, particularly paragraphs QC12 to QC18 (reproduced in Appendix A). Net premiums earned was observed to be a
commonly used measure of revenue under Canadian GAAP prior to the adoption of IFRS, under existing US GAAP and for IFRS preparers in Europe including Aviva plc and Zurich Financial Services Group. Insurance company performance is also typically
measured by the investment community using various ratios, including the combined ratio, expense ratio, and loss ratio, all of which depend on net premiums earned as an input. Therefore the company concluded that net premiums earned was both a
useful measure of revenue for readers of the financial statements and a reasonable measure of revenue among the alternatives available.

 In
addition to presenting net premiums earned, the company has also presented gross premiums written and net premiums written to provide financial statement users insight into the extent of the company’s reliance on reinsurance. Such information,
combined with the disclosures in note 8 (Insurance Contract Liabilities) and note 9 (Reinsurance) to the consolidated financial statements would permit a reader to determine the impact of reinsurance. For example, a reader could determine gross
premiums earned by taking the gross premiums written as disclosed on the statement of earnings in combination with the change in the provision for unearned premiums disclosed in note 8.

 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.

 3

 Company’s Response

 The company acknowledges the guidance in paragraph 25 of IAS 28 that limits the maximum lag to three months when applying the equity method of accounting to its investment in associates. The
company’s financial reporting for its associates complies with this guidance with the exception of two investments in private companies that together had a carrying value of $8.4 and $6.4 at December 31, 2012 and 2011 respectively
(representing 0.6% and 0.7% of the carrying value of the company’s associates, respectively). The company’s share of the pre-tax net earnings (loss) for those two associates totaled $2.0 and ($1.0) for the fiscal years ended
December 31, 2012 and 2011 respectively. One of these associates was subsequently sold in the first quarter of 2013. The company permitted a reporting lag of greater than three months specifically for those two associates on the basis of
materiality, and to a lesser degree, their status as private enterprises that do not provide quarterly financial reports.

 In its future
filings, the company will clarify its accounting policy as disclosed in note 3 (Summary of Significant Accounting Policies) to the consolidated financial statements to state that the difference between the end of its reporting period and that of its
associates is no more than three months. The materiality of any potential differences from this policy will be evaluated in accordance with paragraph 8 of IAS 8 Accounting Policies, Changes in Accounting Estimates and Errors.

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 included 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 for us the authoritative literature you rely upon to support your presentation.

 Company’s Response

 The pledged assets on page 51 of the company’s 2012 Annual
Report, consisting of regulatory deposits and security for reinsurance and other, and those pledged to Lloyd’s on page 78, are primarily included in “Portfolio investments – Bonds” on the consolidated balance sheet.

 4

 The company proposes to add the following disclosure (in bold-faced type) to note 5 (Investments) in its
future filings to address where assets pledged in respect of regulatory deposits and security for reinsurance is recorded:

The table that follows summarizes pledged assets (excluding assets pledged in favour of Lloyd’s (note 20) and assets pledged for
short sale and derivative obligations) by the nature of the pledge requirement. Pledged assets are primarily included within “Portfolio investments – Bonds” on the consolidated balance sheet.

The company proposes to add the following disclosure (in bold-faced type) to note 20 (Contingencies and Commitments) in its future filings to address
where assets pledged to Lloyd’s is recorded:

 OdysseyRe, Advent and RiverStone (UK) (“the Lloyd’s
participants”) participate in Lloyd’s through their 100% ownership of certain Lloyd’s syndicates. The Lloyd’s participants have pledged securities and cash, with a fair value of $604.3 and $24.2 respectively as at
December 31, 2012, in deposit trust accounts in favour of Lloyd’s based on certain minimum amounts required to support the liabilities of the syndicates as determined under the risk-based capital models and on approval by Lloyd’s.
Pledged securities and restricted cash are primarily included within “Portfolio investments – Bonds” and “Portfolio investments – Subsidiary cash and short term investments” respectively, on the consolidated balance
sheet. The Lloyd’s participants have the ability to substitute these securities with other securities subject to certain admissibility criteria. These pledged assets effectively secure the contingent obligations of the Lloyd’s
syndicates should they not meet their obligations. The Lloyd’s participants’ contingent liability to Lloyd’s is limited to the aggregate amount of the pledged assets and their obligation to support these liabilities will continue
until such liabilities are settled or are reinsured by a third party approved by Lloyd’s. The company believes that the syndicates for which the Lloyd’s participants are capital providers maintain sufficient liquidity and financial
resources to support their ultimate liabilities and does not anticipate that the pledged assets will be utilized.

 IFRS 9
Financial Instruments paragraph 3.2.23 provides guidance on the measurement and presentation of financial instruments pledged as collateral. The relevant portion of the IFRS 9 guidance is reproduced below.

If a transferor provides non-cash collateral (such as debt or equity instruments) to the transferee, the accounting for the collateral by
the transferor and the transferee depends on whether the transferee has the right to sell or repledge the collateral and on whether the transferor has defaulted. The transferor and transferee shall account for the collateral as follows:

(a)
If the transferee has the right by contract or custom to sell or repledge the collateral, then the transferor shall reclassify that asset in its statement of financial
position (eg as a loaned asset, pledged equity instruments or repurchase receivable) separately from other assets.

 The
company’s pledged assets in respect of regulatory deposits, security for reinsurance and Lloyd’s participants do not permit the transferee to sell or repledge the collateral. Therefore in accordance with IFRS 9 paragraph 3.2.23, the
company has not segregated those pledged assets on its consolidated balance sheet.

 5

 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 adverse 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 quantifies the
expected impact of on your future financial position and operating results.

 Company’s Response

The statement referred to above by the Staff was in the context of the company’s acquisition of subsidiaries. The company manages adverse
development of prior years’ reserves for acquisitions through extensive due diligence prior to acquisition that includes review of the underlying case reserves and actuarial review. To reduce the level of uncertainty regarding adverse
development of the reserves of acquirees, the company has in the past: (i) required an indemnity from the seller for future adverse development, or (ii) structured a portion of the purchase price to be contingent on the ultimate
development of the prior years’ claims, or (iii) adjusted the purchase consideration to reflect the degree of uncertainty regarding adverse development of reserves. Historical treaties have not been replaced with new treaties because over
time the company is able to ensure its acquired subsidiaries adhere to internal reserving guidelines and measures are also taken to exit lines of business whose risk profiles are not acceptable to the company. Any future adverse development and its
impact on the company’s financial position and operating results stemming from acquired subsidiaries would be analyzed and considered as part of the company’s customary claims reserving and actuarial review processes.

The uncertainty regarding adverse development of the company’s claims reserves (including the claims reserves of acquired subsidiaries) is discussed
extensively in its consolidated financial statements, specifically note 3 (Summary of Significant Accounting Policies), note 8 (Insurance Contract Liabilities), note 9 (Reinsurance), note 24 (Financial Risk Management) and within the MD&A
section entitled “Components of Consolidated Balance Sheets”, specifically the subsections “Provision for Losses and Loss Adjustment Expenses”, “Asbestos and Pollution” and “Recoverable from Reinsurers”.
Therefore the company does not propose any additional