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Mail Stop 6010						July 18, 2005

Mr. John H. Berry
Chief Financial Officer
North Pointe Holdings Corporation
28819 Franklin Road
Southfield, Michigan 48034

Re: North Pointe Holdings Corporation
       Amendment no. 3 to S-1 registration statement
       Filed July 11, 2005
       File No. 333-122220

Dear Mr. Berry:

      We have reviewed your filing and have the following
comments.
Where indicated, we think you should revise your document in
response
to these comments.  If you disagree, we will consider your
explanation as to why our comment is inapplicable or a revision is
unnecessary.  Please be as detailed as necessary in your
explanation.
In some of our comments, we may ask you to provide us with
supplemental information so we may better understand your
disclosure.
After reviewing this information, we may or may not raise
additional
comments.

      Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comments or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Amendment No. 3 to Form S-1

Results of Operations, page 42

Losses and Loss Adjustment Expenses, page 48

Three months ended March 31, 2005 as Compared to Three Months
Ended
March 31, 2004, page 48

1. Refer to your response to comment two.  Your revised disclosure
does not appear to quantify the four factors identified as
contributing to the changes in your loss ratio.  Please revise
your
discussion to quantify the amount of change in your losses caused
by
each or the four factors identified.

Business, page 60

Losses and Loss Adjustment Expenses, page 69

2. We note your revised disclosure in response to our comment
number
five.  Your disclosure still does not appear to analyze how
changes
in the assumptions used would impact the calculation of the
reserves.
Please revise your disclosure to provide quantified and narrative
disclosure of the impact that reasonably likely changes in one of
more of the most significant drivers of the loss reserves would
have
on reported results, financial position and liquidity.

General

      As appropriate, please amend your registration statement in
response to these comments.  You may wish to provide us with
marked
copies of the amendment to expedite our review.  Please furnish a
cover letter with your amendment that keys your responses to our
comments and provides any requested supplemental information.
Detailed cover letters greatly facilitate our review.  Please file
your cover letter on EDGAR under the form type CORRESP.  Please
understand that we may have additional comments after reviewing
your
amendment and responses to our comments.

      We direct your attention to Rules 460 and 461 regarding
requesting acceleration of a registration statement.  Please allow
adequate time after the filing of any amendment for further review
before submitting a request for acceleration.  Please provide this
request at least two business days in advance of the requested
effective date.

      You may contact Tabatha Akins, Staff Accountant at (202)
551-
3658 or  Jim Atkinson, Branch Chief at (202) 551-3674 if you have
questions regarding comments on the financial statements and
related
matters.  Please contact Albert Lee, Staff Attorney at (202) 551-
3654
or John L. Krug, Senior Counsel at (202) 551-3862 with any other
questions.

      			Sincerely,

						Jeffrey Riedler
						Assistant Director

cc: Patrick Daugherty, Esq.
      Todd B. Pfister, Esq.
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