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CORRESP
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corresp

SunTrust Capital Markets, Inc.

3333 Peachtree Road, N.E., 10th Floor

Atlanta, Georgia 30326

September 20, 2005

VIA EDGAR TRANSMISSION

Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

    Re:

    North Pointe Holdings Corporation (the “Company”)

    Registration Statement No. 333-122220

Ladies and Gentlemen:

     Pursuant to Rule 460 of the General Rules and Regulations under the Securities Act of 1933, as
amended (the “Securities Act”), we, as representatives of the several underwriters, wish to advise
you that the following preliminary prospectuses dated September 9, 2005 (contained in the
above-referenced Registration Statement) have been distributed between September 9, 2005 and the
date hereof:

    Class

    Quantity

    Underwriters

    160

    Securities Dealers

    1,005

    Institutional Investors

    2,322

    International

    259

    Retail

    642

    Others

    810

    Total

    5,198

     With respect to Rule 15c2-8 under the Securities Exchange Act of 1934, as amended,
Section 10.8 the Master Agreement Among Underwriters and Sections 3(a) and 3(h) of the Master
Selected Dealer Agreement contain representations that all underwriters and selected dealers will
comply with the requirements of such Rule. In addition, the Underwriting Agreement contains a
covenant from the Company that it will furnish copies of the prospectus in such quantities as the
underwriters may request for the purposes contemplated by the Securities Act. Finally, the
undersigned are taking steps to see that all brokers or dealers participating in the distribution
are promptly furnished with sufficient copies of the preliminary and final

prospectus to enable them to comply with the prospectus delivery requirements of Sections
5(b)(1) and (2) of the Securities Act.

     SunTrust Capital Markets, Inc., through counsel, have been advised verbally by the Corporate
Financing Department of the National Association of Securities Dealers, Inc. that it has reviewed
the above captioned proposed offering and that it has determined to raise no objections with
respect to the fairness of the terms and arrangements of the offering.

     In accordance with Rule 461 under the Securities Act, we hereby join in the request of the
Company for acceleration of the effective date of the above-referenced registration statement so
that it becomes effective at 2:00 p.m. (Eastern time) on September 22, 2005, or as soon as possible
thereafter.

    Very truly yours,

SUNTRUST CAPITAL MARKETS, INC.

WILLIAM BLAIR & COMPANY, L.L.C.

SANDLER O’NEILL & PARTNERS, L.P.

     As Representatives of the Several Underwriters

    By:
    SUNTRUST CAPITAL MARKETS, INC.

    By:
         /s/  John Williams

    Managing Director

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