SecProbe.io

CORRESP
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filename1.htm

   Prepared and filed by St Ives Financial

December 7, 2005

Via EDGAR and FAX

Securities and Exchange
    Commission

  450 Fifth Street, N.W.

  Washington, D.C. 20549

    Attn:
    Jim B.
        Rosenberg

    Senior
        Assistant Chief Accountant

    Division
        of Corporation Finance

    Re:
    Royal & Sun
          Alliance Insurance Group plc

    Form
          20-F for Fiscal Year Ended December 31, 2004 (the “Form 20-F”)

    File
          No. 001-15146

Dear Mr. Rosenberg:

We received your letter
      dated November 28, 2005 (the “letter”) in respect of our Form
      20-F and we noted the 10 business-day response period set forth therein.
      We have
      reviewed the letter and are in the process of preparing a response on an
      expedited basis. However, in light of the detailed nature of some of the
      comments, we believe it will be more appropriate to provide a response
      to the letter by December 19, 2005. We discussed this matter with Frank
      Wyman,
      of the SEC staff, who asked that we formally inform you of our position;
      I trust this is acceptable to you.

Please do not hesitate to contact me at 011 44 20 7111 7117 with any questions.

Yours sincerely,

George Culmer

Chief Financial
Officer

cc:   Frank Wyman, Staff Accountant, Securities and Exchange Commission