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United States securities and exchange commission logo
September 5, 2023
Mark Kociancic
Chief Financial Officer
Everest Re Group, Ltd.
Seon Place - 4th Floor
141 Front Street
PO Box HM 845
Hamilton HM 19, Bermuda
Re:Everest Re Group, Ltd.
Form 10-K for Fiscal Year Ended December 31, 2022
Filed February 24, 2023
File No. 001-15731
Dear Mark Kociancic:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments 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
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K filed February 24, 2023
General
1.We note that you provided more expansive disclosure in your 2021 Corporate Social
Responsibility Report and 2022 Corporate Responsibility Report Supplemental
Disclosures (together, the “CSR Reports”) than you provided in your SEC filings.  Please
advise us what consideration you gave to providing the same type of climate-related
disclosure in your SEC filings as you provided in your CSR Reports.

 FirstName LastNameMark Kociancic
 Comapany NameEverest Re Group, Ltd.
 September 5, 2023 Page 2
 FirstName LastName
Mark Kociancic
Everest Re Group, Ltd.
September 5, 2023
Page 2
Management's Discussion and Analysis of Financial Condition and Results of Operation, page
41
2.To the extent material, discuss the indirect consequences of climate-related regulation or
business trends, such as the following:

•decreased demand for products or services that produce significant greenhouse gas
emissions or are related to carbon-based energy sources;
•increased demand for products or services that result in lower emissions than
competing products;
•increased competition to develop innovative new products that result in lower
emissions;
•increased demand for generation and transmission of energy from alternative energy
sources; and
•any anticipated reputational risks resulting from operations or products that produce
material greenhouse gas emissions.
3.We note disclosure in your Form 10-K that climate change may increase the frequency
and severity of natural catastrophes and the resulting losses in the future and impact your
risk modeling assumptions.  We further note disclosure in your Proxy Statement filed
April 14, 2023, that insured losses due to extreme weather events are increasing over time,
and as climate change worsens, these losses will continue to grow.  Please discuss the
physical effects of climate change on your operations and results.  This disclosure may
include the following:

•severity of weather, such as floods, hurricanes, sea levels, arability of farmland,
extreme fires, and water availability and quality;
•quantification of material weather-related damages to your property or operations;
•potential for indirect weather-related impacts that have affected or may affect your
major customers or insured locations; and
•any weather-related impacts on the cost or availability of (re)insurance.

Include quantitative information for each of the periods covered by your Form 10-K and
explain whether increased amounts are expected in future periods.
4.Your CSR Reports reference a five-year purchase agreement for certified carbon offsets
and voluntary purchases of carbon offset credits.  If material, provide disclosure about
your purchase or sale of carbon credits or offsets and any material effects on your
business, financial condition, and results of operations.  Include quantitative information
for each of the periods covered by your Form 10-K and for future periods in your
response.

 FirstName LastNameMark Kociancic
 Comapany NameEverest Re Group, Ltd.
 September 5, 2023 Page 3
 FirstName LastName
Mark Kociancic
Everest Re Group, Ltd.
September 5, 2023
Page 3
            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.
            Please contact Madeleine Mateo at 202-551-3465 or Jennifer Angelini at 202-551-3047
with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance