SecProbe.io

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Via Facsimile and U.S. Mail
Mail Stop 6010

      October 26, 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 response dated August 9, 2005 to our
comment letter dated July 22, 2005 and have the following
comments.
In our comments, we have asked you to provide us with information
so
we may better understand your disclosure.  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 - December 31, 2004

Item 7.  Management`s Discussion and Analysis of Financial
Condition
and Results of Operations, page 31

Loss and Loss Adjustment Expense Reserves, page 32

1. We believe your proposed disclosures in response to comment
three
could be further improved to better explain the judgments and
uncertainties surrounding this estimate and the potential impact
on
your financial statements.  Please provide us the following
information in disclosure-type format to help us evaluate the
adequacy of your disclosures related to these uncertainties:
* Provide us a revised format of the table included on page 32 to
disclose the amount of IBNR separately from case reserves along
with
your proposed disclosures that you wish to provide with this
information.
* In your response to part b, you infer that multiple point
estimates
are generated that you use to establish your actual reserves.
Please
include the high and low estimates generated by these
calculations.
Also clarify whether you book to the actual estimate generated or
whether that estimate is only used as a basis for your ultimate
liability along with what adjustments you made and the rationale
behind any such adjustments.
* Given the significant impact that these non-core activities have
had on your operations, please enhance your disclosure related to
these activities to include some quantified sensitivity analysis
related to the key factors related to those reserves.

Financial Statements

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

Investments, page 55

2. Refer to your response to comment six.  The accounting for
asset
and mortgage backed securities must typically comply with the
guidance of SFAS 91, SFAS 114, and EITF 99-20.  Please explain to
us
your consideration of this accounting guidance in determining your
accounting policies related to these securities.

*    *    *    *

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

      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) 942-1803.

	Sincerely,

	Jim B. Rosenberg
	Senior Assistant Chief
	Accountant

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Donald J. Zuk
SCPIE Holdings Inc
October 26, 2005
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