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CORRESP
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     Correspondence

Finance
Marcel KAHN

Executive Vice President
Group Chief Financial Officer

UNITED STATES SECURITIES AND

EXCHANGE COMMISSION

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549-6010

Attention :

Jim B. Rosenberg

Senior Assistant Chief Accountant

Paris, September 30, 2005

Via Facsimile and EDGAR

Re:
SCOR
Form
20-F for Fiscal Year Ended December 31, 2004
Filed April 29, 2005
File No. 001-14925

Dear Mr. Rosenberg:

We
are in receipt of your letter dated July 25, 2005 and thank you for your comments
regarding SCOR’s above-referenced filing (the “20-F”). We are
pleased to respond to your questions and to have the opportunity to work with the Staff
of the United States Securities and Exchange Commission (the “Staff”) to
further enhance the overall presentation and disclosure in our filings.

As
more fully described below, we will revise our disclosures effective with our Form 20-F
for the fiscal year ended December 31, 2005 (the “2005 20-F”). The
supplemental information you have requested is provided below. If further clarification
or information is required, please let us know at your earliest convenience.

For
your convenience, we set forth each comment from your comment letter in bold typeface and
include SCOR’s response below it. Capitalized terms used and not defined herein
shall have the respective meanings assigned to them in the 20-F. All references to page
numbers and captions correspond to the page numbers and captions in the 20-F.

SCOR hereby acknowledges that:

•
SCOR
is responsible for the adequacy and accuracy of the disclosure in its filings;

www.scor.com

SCOR

Immeuble SCOR

1, avenue du Général-de-Gaulle

92074 Paris La Défense Cedex

France

Tél. +33 (0)1 46 98 70 00

Fax +33 (0)1 47 67 04 09

e-mail : scor@scor.com

RCS Nanterre B 562 033 357

Siret 562 033 357 00020

Société Anonyme au capital

de 763.096.713 Euros

•
Staff
comments or changes to disclosure in response to Staff comments do not foreclose the
Commission from taking any action with respect to SCOR filings; and

•
SCOR
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.

Form
20-F for Year Ended December 31, 2004

Item 4. Information on the Company

A. Business Overview

Reserves

Changes in Historical Reserves, page 41

1.
We
note from your filing that you have several commutations, which appear to
have materially reduced your loss reserves. Pursuant to the
requirements of Industry Guide 6, Disclosures Concerning Unpaid
Claims and Claim Adjustment Expense of Property-Casualty Insurance
Underwriters, please disclose all your significant
commutation and/or portfolio transfers and the effect each commutation
and/or portfolio transfer had on your financial condition and results
of operations.

SCOR respectfully submits to the Staff that there were no significant commutations prior to
January 1, 2003.

As
disclosed in the 20-F, in January 2003, SCOR put the operations of its Bermudan
subsidiary, CRP, in run-off and, in accordance with the “Back on Track” plan
launched by SCOR in 2002, SCOR determined to withdraw from certain other lines of
business at SCOR U.S.’s operations. A significant part of SCOR’s strategy
includes the commutation, as appropriate, of the run-off business.

SCOR would respectfully propose to include the following additional information in its 2005
20-F:

In
2003, CRP’s reserves were reduced on the balance sheet by approximately EUR 577
million, due to two significant commutations. These commutations in 2003 reduced the
Group results of operations for the year ended December 31, 2003 by approximately EUR 26
million, before taxes.

In 2004, the reduction in reserves on the balance sheet due to significant commutations
amounted to approximately EUR 26 million at CRP, and approximately EUR 60 million at
SCOR U.S. The commutations in 2004 did not have a material effect on the Group results of
operations for the year ended December 31, 2004.

www.scor.com

SCOR

Immeuble SCOR

1, avenue du Général-de-Gaulle

92074 Paris La Défense Cedex

France

Tél. +33 (0)1 46 98 70 00

Fax +33 (0)1 47 67 04 09

e-mail : scor@scor.com

RCS Nanterre B 562 033 357

Siret 562 033 357 00020

Société Anonyme au capital

de 763.096.713 Euros

2

Item 5. Operating and Financial Review and Prospects

A. Operating Results

Consolidated Results of Operations

Expenses, page 62

2.
It
appears that you have significantly revised your estimate of loss reserves
recorded in prior years. Please revise Management’s Discussion
and Analysis to explain the reason for your change in estimate. For
each line of business, include 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.
Identify
the changes in the key assumptions you made to estimate the reserve since
the last reporting date.

c.
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.

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

e.
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.

In response to your
comment, please be advised that in 2004 SCOR on a consolidated basis, did not
significantly revise its estimates of loss reserves recorded in prior years.

SCOR would
respectfully propose to include the following additional information in its 2005 20-F:

During the period from
the 2000 to 2003 balance sheet years, newly obtained experience data for the industry in
general and SCOR revealed medical cost inflation significantly exceeding original
projections. This caused SCOR and other members of the industry to reevaluate the impact
of medical costs on all of the reserves for U.S. Casualty lines of business, particularly
those relating to U.S. workers compensation for underwriting years 1997, 1998, 1999 and
2000. The increase in reserves on the balance sheet at SCOR U.S. over the period totaled
approximately EUR 929 million comprising an increase of EUR 206 million, 201 million, 197
million and 325 million in 2000, 2001, 2002 and 2003, respectively. These increases in
reserves were reflected in Property-Casualty claims in the consolidated statement of
operations for the corresponding year. No change in actuarial methods was made.

www.scor.com

SCOR

Immeuble SCOR

1, avenue du Général-de-Gaulle

92074 Paris La Défense Cedex

France

Tél. +33 (0)1 46 98 70 00

Fax +33 (0)1 47 67 04 09

e-mail : scor@scor.com

RCS Nanterre B 562 033 357

Siret 562 033 357 00020

Société Anonyme au capital

de 763.096.713 Euros

3

SCOR also revised the reserves corresponding to CRP’s business in 2000 to 2003. The net
technical result of these operations corresponded respectively to a loss of EUR 14
million in 2000, a loss of EUR 60 million in 2001, a loss of EUR 240 million in 2002 and
a loss of EUR 170 million in 2003. These increases in reserves were reflected in
Property-Casualty claims in the consolidated statement of operations for the
corresponding year. No change in actuarial methods was made.

B. Liquidity and Capital Resources

Liquidity and Capital Resources, page 67

3.
Please
include in MD&A a more robust discussion of the reasonably likely
impact the payment of claims will have on known trends and
uncertainties, in particular cash outflows from operations. In the
disclosure please include a discussion of your asset/liability management
process and whether there are any significant variations
between the maturity of your investments and the expected payment
of your loss reserves. Include a discussion of the impact of selling
securities before anticipated or the use of credit facilities to pay for policy
liabilities will have on your future liquidity and results of
operations.

SCOR would respectfully propose to include the following additional information in its 2005
20-F:

Our operating cash outflows include claim settlements. Since cash inflow from premiums is
received in advance of cash outflow required to settle claims we accumulate funds that we
invest. SCOR’s asset/liability management strategy entails minimizing asset risk,
since SCOR’s core business activity, reinsurance, can expose SCOR to significant
uncertainty regarding the expected timing of its liabilities. In addition, changes in SCOR’s
underwriting strategy and the run-off of certain business segments have impacted the
composition of SCOR’s liabilities. Consequently, SCOR has historically maintained a
conservative investment policy. In general, SCOR invests in liquid, high-grade
securities, with a majority (63%, 64% and 63% for each of 2002, 2003 and 2004,
respectively) of its investments in fixed maturities, and a significant portion of its
investments in cash and cash equivalents (20%, 22% and 21% for each of 2002, 2003 and
2004, respectively) in order to maintain sufficient liquidity to meet its expected
liabilities together with a reasonably possible deviation from these expected
liabilities. As a result, liquidation of fixed maturity securities should not be
necessary in the ordinary course of business. As a general practice, the Group does not
invest in derivative securities for the purpose of managing the relative duration of its
assets and liabilities. Similarly, assets are generally invested in currencies
corresponding to those in which the related liabilities are denominated in order to
minimize exposure to currency fluctuations. The Group does use currency spot and forward
contracts, as well as swap and other derivative contracts, to a limited extent, to manage
its foreign currency exposure.

D. Contractual Obligations, page 72

4.
We
note that you have not included property-casualty and life reserves to be
paid 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

www.scor.com

SCOR

Immeuble SCOR

1, avenue du Général-de-Gaulle

92074 Paris La Défense Cedex

France

Tél. +33 (0)1 46 98 70 00

Fax +33 (0)1 47 67 04 09

e-mail : scor@scor.com

RCS Nanterre B 562 033 357

Siret 562 033 357 00020

Société Anonyme au capital

de 763.096.713 Euros

4

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. In addition, please include interest payments on long term debt.

Due
to the inherent uncertainty contained in reserves estimates and in projected payment
patterns, SCOR respectfully submits to the Staff that the inclusion of claims cash flow
information would not be meaningful to readers, particularly due to recent changes in SCOR’s
underwriting strategy and the run-off of certain business segments, which have impacted
the composition of SCOR’s liabilities and which make historical data less meaningful
to readers.

In
its 2005 20-F SCOR would respectfully propose to include in the contractual obligations
table a line item captioned “Long term debt (interest)". SCOR supplementally
advises the Staff that such information as of December 31, 2004 is as set forth in the
table below:

     Total
     Less

than

1 year
     1-3

years
     3-5

years
     More

than 5

years

     Long term debt
(interest)*
     218
     30
     68
     23
     97

 * Some of SCOR’s long term debt bears interest at floating rates and is denominated in
U.S. dollars. The calculation of interest payments on long term debt is based on interest
rates and exchange rates as of December 31, 2004.

G. Critical Accounting Policies

Technical Reserves, page 73

5.
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 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 revise MD&A to include
the following information for each of your lines of business.

a.
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. In addition include quantified and narrative
disclosure of the

www.scor.com

SCOR

Immeuble SCOR

1, avenue du Général-de-Gaulle

92074 Paris La Défense Cedex

France

Tél. +33 (0)1 46 98 70 00

Fax +33 (0)1 47 67 04 09

e-mail : scor@scor.com

RCS Nanterre B 562 033 357

Siret 562 033 357 00020

Société Anonyme au capital

de 763.096.713 Euros

5

impact that
reasonably likely changes in one or more of the variables (i.e. actuarially method and/or
assumptions used) would have on reported results, financial position and liquidity.

b.
If
you do not calculate a range around your loss reserve, but instead use
point estimates please include the following disclosures:

•
Disclose
the various methods considered and the method that was selected to calculate the
reserves. If multiple point estimates are generated, include the range of these
point estimates. Include a discussion of why the method selected was more
appropriate over the other methods.

•
Discuss
how management determined the most appropriate point estimate and why the other point
estimates were not chosen. Also clarify whether the company actually records to
the point estimate or if not, how that estimate is used.

•
Include
quantified and narrative disclosure of the impact that reasonably likely changes in one
or more of the variables (i.e. actuarially method and/or assumptions used) would
have on reported results, financial position and liquidity.

c.
Because
IBNR reserve estimates are more imprecise, please disclose the amount of
IBNR separately from case reserves for all lines of business.

d.
For
each line of your longer tail business with claims for asbestos-related
illnesses, environmental remediation, product liability and other
highly uncertain exposures, please provide more precise insight
into the existence and effects on future operations and financial
condition of known trends, events and uncertainties. Disclosure you
should consider, but not be limited to, includes the following
information:

•
the number of claims pending at each balance sheet date;

•

 the number of claims reported for each period presented;

•

  the number of claims dismissed, settled, or otherwise resolved for each period;

•

the nature of the claims including relevant