SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

August 22, 2005
Mr. Donald J. Zuk
President and Chief Executive Officer
SCPIE Holdings Inc.
1888 Century Park East
Los Angeles, CA   90067

Re:	SCPIE Holdings Inc.
	Form 10-K for fiscal year ended
	December 31, 2004
	Filed March 16, 2005
	File No. 001-12449

Dear Mr. Zuk:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to those issues we have
addressed in our comments.  In our comments, we ask you to provide
us
with information so we may better understand your disclosure.
Please
be as detailed as necessary in your explanation.  After reviewing
this information, we may raise additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for the fiscal year ended December 31, 2004

Loss and Loss Adjustment Expense (LAE) Reserves, page 11
1. Please explain to us why you limited your reconciliation to
gross
in these tables to the reserves only and did not include your
deficiencies/redundancies on a gross basis.

2. It appears that management significantly revised its estimate
of
loss reserves recorded in prior years.  Please provide us the
following information in disclosure-type format to help us
evaluate
the adequacy of your disclosure related to the reasons for these
changes in estimate.  For each line of business, provide the
following disclosures:

* Identify the years to which the change in estimate relates and
disclose the amount of the related loss reserve as of the
beginning
of the year that was re-estimated.  Discuss and quantify
offsetting
changes in estimates that increase and decrease the loss reserve.
* Quantify the effects of all changes discussed such as the
favorable
experience related to core business discussed in the fourth
paragraph
from the end of this section on page 14.
* Identify the changes in the key assumptions made to estimate the
reserve since the last reporting date.
* Identify the nature and timing of the change in estimate,
explicitly identifying and describing in reasonable specificity
the
new events that occurred or additional information acquired since
the
last reporting date that led to the change in estimate.
* Ensure the disclosure clearly explains why recognition occurred
in
the periods that it did and why recognition was not required in
earlier periods.
* Disclose any trends such as, the number of claims incurred,
average
settlement amounts, number of claims outstanding at period ends
along
with average per claim outstanding, and any other trends,
necessary
to understand the change in estimate. Please explain the rationale
for a change in estimate that does not correlate with trends.

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 21

Loss and Loss Adjustment Expense Reserves, page 32
3. We believe your disclosure in Management`s Discussion and
Analysis
regarding the reserve for loss and loss adjustment expenses could
be
improved to better explain the judgments and uncertainties
surrounding this estimate and the potential impact on your
financial
statements.  We believe that disclosures explaining the likelihood
that any materially different amounts would be reported under
different conditions or using different assumptions is consistent
with the objective of Management`s Discussion and Analysis.
Accordingly, please provide us the following information in
disclosure-type format to help us evaluate the adequacy of your
disclosure in MD&A related to these uncertainties for each of your
lines of business.

* Because IBNR reserve estimates are more imprecise, please
disclose
the amount of IBNR separately from case reserves in the table
included on page 32.
* Include a more detailed discussion of your reserving process in
your discussion within the business section beginning on page 11.
Such discussion should provide a more robust discussion of the key
drivers that affect the amounts of these reserves.
* If you develop a range of losses related to these reserves,
please
disclose the range of loss reserve estimates as determined by your
actuaries.  Discuss the key assumptions used to arrive at
management`s best estimate of loss reserves within that range and
what specific factors led management to believe this amount rather
than any other amount within the range represented the best
estimate
of incurred losses.
* If you do not develop a range of losses, please provide
additional
sensitivity analysis related to these reserves.  We note your
disclosure on page 14 of the impact a change in "pure loss costs
trend" would have related to your core business.  In addition to
this
disclosure, provide some discussion of the "non-core" reserves
given
the significant impact that changes in these reserves have had on
recent operations.  Please note that the mathematical calculation
included in the last paragraph of this section on page 32 does not
provide sufficient insight into the true sensitivity of these
reserves to the actual key assumptions.

Contractual Commitments, page 40

4. We note that you did not include your losses and loss
adjustment
expense reserves in the contractual obligation table, and it would
appear that these liabilities represent future legal obligations
of
the Company.  Due to the significant nature of these liabilities
to
your business we believe the inclusion of reserves in the
contractual
obligation table will provide investors increased disclosure of
your
liquidity.  The purpose of Financial Reporting Release 67 is to
obtain enhanced disclosure concerning a registrant`s contractual
payment obligations and the exclusion of ordinary course items
would
be inconsistent with the objective of the Item 303(a)(5) of
Regulation S-K.  Based on the above factors, please revise your
contractual obligation table to include the expected settlement of
your loss reserves.

Other Operations, page 38

5. Please explain to us why you recognized such a significant
amount
of "Net realized investment gains" for the 2002 fiscal year.
Include
why you did not appear to address this significant gain in your
discussion of operations.

Note 1.  Nature of Operations and Significant Accounting Policies,
page 55

Investments, page 55

6. It appears that you include mortgage and asset backed
securities
as available for sale.  Please clarify for us what your accounting
policy is related to these types of investments.

Note 4.  Reinsurance, page 60

7. In your discussion of the amount of premiums ceded as part of
the
Rosemont transaction, you disclose the premiums ceded under that
agreement.  Please clarify for us how the amounts disclosed in
that
discussion reconcile to the amounts disclosed in the table at the
top
of page 61 given that they appear to exceed "Ceded" premiums as
disclosed in that table for certain periods.

      Please furnish a cover letter with your response that keys
your
responses to our comments and provides any requested information
within ten business days.  Detailed cover letters greatly
facilitate
our review.

*    *    *    *

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing include all information required under the Securities
Exchange
Act of 1934 and that they have provided all information investors
require for an informed investment decision.  Since the company
and
its management are in possession of all facts relating to a
company`s
disclosure, they are responsible for the accuracy and adequacy of
the
disclosures they have made.

	In connection with responding to our comments, please
provide,
in your letter, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;

* 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
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

      In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Ibolya Ignat, Staff Accountant at (202) 551-
3656, or Jim Atkinson, Accounting Branch Chief, at (202) 551-3674
if
you have questions regarding the comments. In this regard, do not
hesitate to contact me, at (202) 551-3679.

							Sincerely,

							Jim B. Rosenberg
							Senior Assistant Chief
Accountant
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Donald J. Zuk
SCPIE Holdings Inc.
August 22, 2005
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