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December 17, 2021
Scott Kirk
Chief Financial Officer
Argo Group International Holdings, Ltd.
90 Pitts Bay Road
Pembroke HM 08
Bermuda
Re:Argo Group International Holdings, Ltd.
Form 10-K for Fiscal Year Ended December 31, 2020
Filed March 15, 2021
File No. 001-15259
Dear Mr. Kirk:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment.  In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
            Please respond to this comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional comments.
Form 10-K filed March 15, 2021
Note 2. Revisions of Previously Issued Financial Statements, page F-17
1.We note your disclosure that you identified certain immaterial errors in your historical
financial statements primarily related to the accounting for (1) foreign currency exchange
gains and losses associated with a specific reinsurance contract and (2) errors in the
Company’s tax provision primarily related to the Company’s allocation of certain
corporate-level expenses to your subsidiary companies, as well as other previously
identified immaterial errors. We further note your disclosure that you concluded that
although these errors were not material to the previously issued financial statements,
however, correcting the cumulative effect of the errors in 2020 would materially misstate
the 2020 consolidated financial statements, and therefore you have revised your historical
financial statements to correct for these immaterial errors. In light of the nature of the
errors and their quantitative significance to the adjusted financial statements presented,

 FirstName LastNameScott Kirk
 Comapany NameArgo Group International Holdings, Ltd.
 December 17, 2021 Page 2
 FirstName LastName
Scott Kirk
Argo Group International Holdings, Ltd.
December 17, 2021
Page 2
including, for instance income tax provision, net income (loss) and earnings per share for
certain of the revised periods, please provide us with your analysis considering the
guidance in Staff Accounting Bulletin No. 99. In your response please discuss how you
evaluated the total mix of information, taking into account both quantitative and
qualitative factors considered, when determining materiality of the error to investors and
other users.
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact William Schroeder at 202-551-3294 or John Spitz at 202-551-3484 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Finance