SecProbe.io

September 17, 2013

Via E-mail
Mr. Larry G. Swets, Jr.
President and Chief Executive  Officer
Kingsway Financial Services, Inc.
45 St. Clair Avenue West, Suite 400
Toronto, Ontario,  Canada M4V 1K9

Re: Kingsway Financial  Services , Inc.
  Form 10-K for Fiscal Year Ended December 31, 201 2
  Filed March 22 , 2013
File No. 001-15204

Dear  Mr. Swets :

We have limited our review to only your financial statements and related
disclosures and do not intend to expand our review to other portions of your document.
In our comment s, we ask you to provide us with information so we may better understand
your disclosure.

Please respond to this letter within 10 business days by  providing the requ ested
information or by advising us when you will provide the requested response.   If you do
not believe a comment applies to your facts and circumstances, please tell us why in your
response.   Please furnish us a letter on EDGAR under the form type label CORRESP that
keys your response s to our comment s.

After reviewing the information provided, we may raise additional comments
and/or request that you amend your filing.

Notes to Consolidated Financial Statements

Note 11 Intangible Assets, page 69

1. Please provide us a robust analysis supporting your conclusion that renewal rights
at January 1, 2011 became  indefinite -lived intangible assets  and no longer subject
to amortization .  In addition, please explain why these rights were not impaired at
December  31, 2012, given your risk factor disclosures on pages 19 and your
assertions on page 75 that your operations remain challenged and as a result  the
company’s  ability to utilize losses reflected in its deferred tax assets is uncertain.

Mr. Larry G. Swets, Jr.
Kingsway Financial Services, Inc.
September 17, 201 3
Page 2

 Note 29 Statutory  Balances and Accounting Practices, page 87

2. Regarding your disclosure that statutory amounts for the latest period are
unaudited, please represent to us that you will remove this designation in future
filings as this information is required by ASC 944 -505-50-1a.  To the extent you
intended to express that the audits of your statutory financial statements were not
yet complete at the time you issued your financial statements, we do not believe
that the timing of regulatory filings is relevant to disclosures  required by GAAP.

3. Although you disclose in Note 28 that each of your insurance subsidiaries, with
the exception of Amigo, exceeded the 200% risk -based capital ratio threshold,
please provide us proposed disclos ure to be included in future periodic reports of
the amount of statutory capital and surplus necessary to satisfy regulatory
requirements if significant in relation to actual statutory capital and surplus, as
required under ASC 944 -505-50-1b.  If not signi ficant, please clarify in the
disclosure by providing an indication of the magnitude of the excess at your
insurance subsidiaries other than Amigo.

We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing to be certain that the filing includes the information the Securities
Exchange Act of 1934 and all applicable Exchange Act rules require.   Since the company
and its management are in possession of all facts relating to a company’s disclosure, they
are respons ible for the accuracy and adequacy of the disclosures they have made.

In responding to our comments, please provide  a written statement from the
company acknowledging that:
 the company is responsible for the adequacy and accuracy of the disclosure in t he
filing;
 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 th e Commission or any person under the federal securities laws of the
United States.

Please contact Frank Wyman, Staff Accountant, at (202) 551 -3660  or Mark
Brunhofer , Senior Staff Accountant , at (202) 551 -3638 if you have any questions
regarding th e commen ts. In this regard, do not hesitate to contact me at (202) 551 -3679.

Sincerely,

/s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief
Accountant