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Letter of Correspondence

 September 9, 2005

 Mr. Jim B. Rosenberg

 Senior Assistant Chief Accountant

 Securities and Exchange Commission

 450 Fifth Street N.W.

 Washington, D.C. 20549

Re:

SCPIE Holdings Inc.

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

Filed March 16, 2005

Commission File No. 001-12449

 Dear Mr. Rosenberg:

 We are in receipt of the Staff’s letter dated August 22, 2005 with respect to the above
referenced 10-K of SCPIE Holdings Inc. (“the Company”). This letter is being provided in response to the comments raised by the Staff as set forth below. Courtesy copies of this letter are being submitted to the Staff by facsimile
delivery. The Company’s responses are numbered to correspond to the numbered comments in the Staff’s letter. All capitalized terms used but not defined herein have the meanings assigned to such terms in the Form 10-K. For ease of
reference, we have set forth the Staff’s comments and the Company’s response for each item below.

 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.

 Company Response:

 In future Annual Reports on Form 10-K, the Company will provide additional information below
the table found on page 13 of the 2004 10-K to reconcile the net deficiency/redundancy to the gross deficiency/redundancy by adding the following lines:

 Gross re-estimated liability – latest period

xxx

 Re-estimated reinsurance recoveries

xxx

 Net re-estimated Liabilities – latest period

xxx

 Net liability cumulative redundancy/deficiency

xxx

 Gross liability cumulative redundancy/deficiency

xxx

 Additional explanatory language will
be added preceding the table to describe the new lines added.

 Mr. Jim B. Rosenberg

 Securities and Exchange Commission

 September 9, 2005

 Page 2

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:

a.
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.

b.
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.

c.
Identify the changes in the key assumptions made to estimate the reserve since the last reporting date.

d.
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.

 Mr. Jim B. Rosenberg

 Securities and Exchange Commission

 September 9, 2005

 Page 3

e.
Ensure the disclosure clearly explains why recognition occurred in the periods that it did and why recognition was not required in earlier periods.

f.
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.

 Company Response:

 In future Annual Reports on Form 10-K, the following type of disclosure would replace the disclosure under the table on page 13 through the heading Ceded Reinsurance
Programs on page 14.

 Prior to the Company’s expansion outside of its
California healthcare liability markets beginning in 1997, the Company had historically experienced favorable development in loss and LAE reserves established for prior years. The Company believes that the favorable loss and LAE reserve development
resulted from four factors: (i) the Company’s conservative approach of establishing reserves for medical malpractice insurance losses and LAE; (ii) the continuing benefits from the Medical Injury Compensation Reform Act (MICRA), the California
tort reform legislation that was declared constitutional in a series of decisions by the California Supreme Court in the mid-1980s; (iii) benefits from California legislation requiring matters in litigation to proceed more expeditiously to trial;
and (iv) improved results from a restructuring of the Company’s internal claims process. The Company believes, based on its analysis of annual statements filed with state regulatory authorities, that its principal California competitors
experienced similar favorable loss and LAE reserve development in those years.

 The Company’s reserve analysis (and its independent consulting actuaries’ analysis) began to exhibit less variability related to the core California healthcare liability business from 1999 forward as the effects of the items
mentioned in the preceding paragraph were reflected in the historical loss and LAE data which is the foundation of actuarial estimates. As this variability decreased, the Company’s core business reserve estimates, although still considered
conservative, were inherently less variable than before.

 Mr. Jim B. Rosenberg

 Securities and Exchange Commission

 September 9, 2005

 Page 4

 During the last three years, the core California healthcare
liability markets have seen significant decreases in the frequency of claims per exposure of a cumulative 21%. This has been only partially offset by increases in the average severity of claims. The reduced frequency and the lack of significant
policy limit claims have primarily generated the favorable development observed in the core-healthcare liability reserves.

 The Company’s core healthcare liability businesses have had favorable developments of $41.1 million, $15 million, $22.8 million and $8.9 million in 2001, 2002, 2003
and 2004 respectively. These favorable developments represented 17.0%, 6.3%, 9.7% and 3.6% of the preceding year end net reserves respectively.

 The primary trend affecting the adequacy of reserve estimates in the core area is the trend in pure loss costs (the combination of frequency and average severity changes)
related to malpractice coverage. The inherent pure loss cost trend included in the setting of the 2002, 2003 and 2004 reserves has been 6.7%, 4.4% and 3.3%, respectively. At 2004 reserve levels, a 1% change in the pure loss costs trend produces a
change in prior reserves of approximately $5.3 million. Such changes in estimates are reflected in the period of change. Reserves related to medical malpractice coverage account for 90% of core reserves.

 The cumulative deficiencies which have emerged for reserves held over the past four years
relate entirely to the Company’s non-core healthcare liability and assumed reinsurance reserves which are now in run-off.

 Beginning with the Company’s expansion into hospital (1997) and healthcare liability outside of California (1998) and assumed reinsurance (mid 1999), the reserve
estimation process became significantly more volatile. The healthcare liability business outside of California did not have the benefits of MICRA-type reform and assumed reinsurance business is, by its nature, extremely volatile.

 Because the Company’s expansion into the hospital and the healthcare liability outside
of California represented new areas for which the Company had limited historical experience, the Company primarily

 Mr. Jim B. Rosenberg

 Securities and Exchange Commission

 September 9, 2005

 Page 5

 utilized industry experience to estimate required reserve
levels. There were significant increases in severity trends in these areas beginning in 2000. Although the Company took significant rate action and underwriting restrictions were implemented, ultimately the Company withdrew from these markets
(hospitals in 2001 and non-core healthcare physician business in 2002).

 The
non-core healthcare incurred losses have included upward development of $46.0 million, $16.8 million, $7.2 million and $6.0 million for the years ended 2001, 2002, 2003, and 2004 respectively. These upward developments represented 39.5%, 9.6%, 4.0%
and 4.1% of the preceding year-end net reserves respectively. The need for these reserve changes arose as the actual extent and size of increases in the frequency and severity of claims related to the non-core healthcare liability emerged in the
actuarial data used to project these losses, most notably in 2001 and 2002. The Company believes similar increases were recognized by many companies in the industry at that time.

 The Assumed Reinsurance operations encompassed various aspects of the worldwide reinsurance market. The Company has relied heavily on the
ceding companies in establishing loss reserves including IBNR.

 Upward
development has occurred in the assumed reinsurance reserves of $15.4, $7.2 and $15.2 during 2002, 2003 and 2004. This represents 18.2%, 6.3% and 14.3% of the preceding year’s net reserves. The development of assumed reinsurance in 2002 and
2003 was principally as a result of upward development in the reinsurance markets estimate and settlement of losses that related to the World Trade Center terrorist attack in 2001. The upward development in 2004 was principally due to the sudden
collapse in 2004 of one bonding program ($5.6 million), late reported losses in 2004 related to one excess of loss liability treaty which includes directors and officers liability ($4.8 million), and changes in actuarial estimates of Lloyd’s
syndicates in 2004 ($3.7 million).

 Mr. Jim B. Rosenberg

 Securities and Exchange Commission

 September 9, 2005

 Page 6

 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.

a.
Because IBNR reserve estimates are more imprecise, please disclose the amount of IBNR separately from case reserves in the table included on page 32.

 Company Response:

 The Company is troubled by your request to state IBNR separately along with case reserves.
Our concern relates to the practical way that IBNR is derived in the actuarial review process. For most, if not all medical malpractice and other long tail lines of liability business, IBNR is the mathematical result of subtracting tabular case
reserves from projected ultimate losses derived by various actuarial projection techniques. IBNR reserves in the case of medical malpractice insurance written on a claims-made reporting policy (almost always) does not represent late reported claims
but rather upward case reserve movement which will be recognized in case reserves when more data will allow for a more accurate review of liability and loss exposure on an individual facts and circumstances basis. The Company is concerned that by
disclosing IBNR separately from case reserves, analysts and readers of insurance company financial statements will assume a level of accuracy that is not appropriate without some measure of the company’s case reserving philosophy compared to
others in the industry. If we did disclose IBNR

 Mr. Jim B. Rosenberg

 Securities and Exchange Commission

 September 9, 2005

 Page 7

 separately for case reserves, we would also include commentary
warning of the potential erroneous conclusions that could be derived by comparing an individual company’s numbers to any other insurance company.

b.
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.

 Company Response:

 Along with disclosures currently
made in the Company’s 2004 10-K, we would add the following type disclosures after the paragraphs on page 11 in future reports on Form 10-K:

 The Company and its consulting actuaries use a variety of actuarial methodologies in evaluating the adequacy of healthcare liability loss and LAE reserves. Loss
development methods use historical loss development patterns by report year and the valuation points of reported losses. Paid loss and reported incurred loss development projections are base methods and are used to support the other techniques.
Report year claim count and severity (average claim size) projections are developed to provide alternative projections using reported claim frequency and trended severity. Alternative reported projections are developed by adjusting the claims
settlement rates so that these patterns are consistent from year to year. Trended pure premium projections are developed by trending average losses per exposure from mature periods. The Company also uses the Bornhuetter-Ferguson method which
combines reported losses, loss development patterns and expected loss ratios.

 The indications derived under the various methodologies are analyzed by limit, resulting average loss trends, age of accident year and known policy limit claims outstanding. An individual reserve level is selected by accident/report year.

 Mr. Jim B. Rosenberg

 Securities and Exchange Commission

 September 9, 2005

 Page 8

 Loss development methods based on historical patterns are very
sensitive to small changes in the pattern of loss payment or reported losses. Methods which determine trends from mature periods or use expected loss ratios are less sensitive to changes in loss payment or reporting patterns. In general, the
Bornhuetter-Ferguson and trended pure premium loss methodologies are given more weight in selecting the levels for the most recent accident years. As more data emerges in payments and settled claims, the various methodologies begin to converge.

 In the assumed reinsurance area, the Company and their consulting actuaries
rely heavily on other work performed by internal and independent actuaries of the ceding companies. This work is reviewed, where appropriate, as well as general industry patterns applied to other data. The volatility is greatest in those areas where
claims take a long time, often many years, to be reported through the worldwide reinsurance market.

c.
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.

 Company Response:

 Neither the Company nor its consulting actuary develops a range of reserves related to
losses and LAE.

d.
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 imp