SecProbe.io

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                      PLATINUM UNDERWRITERS HOLDINGS, LTD.
                             The Belvedere Building
                                69 Pitts Bay Road
                             Pembroke, Bermuda HM 08

                                          August 15, 2005

Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
Securities and Exchange Commission
Division of Corporation Finance

Mail Stop 6010
100 F Street, N.E.
Washington, D.C. 20549

   Re:  Form 10-K for the Year Ended December 31, 2004
   File Number: 001-31341 (the "2004 10-K")

Dear Mr. Rosenberg:

            The following information is provided by Platinum Underwriters
Holdings, Ltd. ("Platinum Holdings") in response to the comments issued by the
staff of the Division of Corporation Finance of the Securities and Exchange
Commission (the "Staff") by letter dated August 3, 2005 (the "Comment Letter")
as a result of the Staff's examination of the above-referenced document.

            For ease of reference, the Staff's comments are included herein in
bold followed by our responses. In response to the Staff's request to provide
additional disclosure regarding certain aspects of our business, results of
operations and financial condition, we have furnished as exhibits hereto
relevant excerpts from our 2004 10-K to which we have added the requested
disclosure as highlighted.

            We note that you have requested that we amend our 2004 10-K to
provide the additional disclosure requested. In that regard, please be advised
that we received a separate comment letter (the "Second Comment Letter") on a
Registration Statement on Form S-4 that we filed with the Securities and
Exchange Commission on July 26, 2005 (File Number 333-126883) (the "S-4"), a
copy of which is attached hereto for your convenience as Appendix I. We propose
that, rather than amend our 2004 10-K, we include the additional disclosure
requested in the Comment Letter in a pre-effective amendment to our S-4, along
with the additional disclosure requested in the Second Comment Letter. We would
also include such disclosure in our Quarterly Report on Form 10-Q for the
Quarter Ended September 30, 2005, our Annual Report on Form 10-K for the Year
Ended December 31, 2005, and all of our subsequent filings pursuant to the
Securities Exchange Act of 1934, in each case as appropriate.
<PAGE>
            In order facilitate this coordinated approach, we are sending a copy
of this response to each of Jeffrey P. Riedler, Song Brandon and Suzanne Hayes,
the members of the Staff who reviewed the S-4. In addition, to facilitate your
review, we are sending to you, as well as to Dana Hartz and to Joseph Roesler,
five copies of this response by Federal Express today.

FORM 10-K FOR THE FISCAL YEAR ENDED DECEMBER 31, 2004

BUSINESS

FINITE RISK, PAGE 10

1.    WE NOTE FROM YOUR DISCLOSURE THAT YOU OFFER FINITE REINSURANCE AND BELIEVE
      IT CAN BE EXPANDED UPON. PLEASE DISCLOSE FOR EACH MAIN CATEGORY OF FINITE
      RISK CONTRACTS:

      a.    THE ECONOMIC BENEFIT THAT YOU ARE ATTEMPTING TO PROVIDE TO THE
            CEDING COMPANIES.

      b.    WHETHER THE PROTECTION IS PROSPECTIVE OR RETROSPECTIVE.

      c.    ANY PROVISIONS IN THE CONTRACTS AND/OR TREATIES THAT ARE NOT USUALLY
            INCLUDED IN A STANDARD REINSURANCE CONTRACT (I.E. CERTAIN RISK
            MITIGATION FEATURES).

            In response to the comments set forth in this paragraph 1, we have
            included additional disclosure in the excerpt from our 2004 10-K set
            forth in Exhibit A.

MANAGEMENT'S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF
OPERATIONS

CRITICAL ACCOUNTING POLICIES

PREMIUMS, PAGE 35

2.    WE BELIEVE YOUR DISCLOSURE IN MANAGEMENT'S DISCUSSION AND ANALYSIS
      REGARDING THE ESTIMATE OF ASSUMED PREMIUM ON YOUR REINSURANCE BUSINESS
      COULD BE IMPROVED TO BETTER EXPLAIN THE JUDGMENTS AND UNCERTAINTIES
      SURROUNDING THIS ESTIMATE AND THE POTENTIAL IMPACT ON YOUR FINANCIAL
      STATEMENTS. ACCORDINGLY, PLEASE REVISE MD&A TO INCLUDE THE FOLLOWING
      INFORMATION:

      a.    DISCUSS THE KEY ASSUMPTIONS USED TO ARRIVE AT MANAGEMENT'S BEST
            ESTIMATE OF THE PREMIUMS WRITTEN BUT NOT REPORTED ESTIMATE AND THE
            PREMIUMS EARNED BUT NOT REPORTED ESTIMATE, AND WHAT SPECIFIC FACTORS
            LED MANAGEMENT TO BELIEVE EACH ASSUMED PREMIUM ESTIMATES ARE THE
            MOST REALISTIC.

                                       2
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      b.    INCLUDE QUANTIFIED AND NARRATIVE DISCLOSURE FOR EACH OF YOUR PREMIUM
            ESTIMATES OF THE IMPACT THAT REASONABLY LIKELY CHANGES IN ONE OR
            MORE OF THE VARIABLES (I.E. METHODOLOGY AND/OR ASSUMPTIONS USED)
            WOULD HAVE ON REPORTED RESULTS, FINANCIAL POSITION AND LIQUIDITY.

      c.    DISCLOSE THE PROVISION FOR DOUBTFUL ACCOUNTS THAT IS RECORDED
            RELATED TO THE ASSUMED PREMIUM ESTIMATE.

            In response to the comments set forth in this paragraph 2, we have
            included additional disclosure in the excerpt from our 2004 10-K set
            forth in Exhibit B.

UNPAID LOSSES AND LAE, PAGE 36

3.    WE NOTE THAT YOU SET YOUR CLAIM RESERVES FOR ASSUMED REINSURANCE
      OPERATIONS BASED UPON INFORMATION RECEIVED FROM THE CEDANT. AS THIS
      APPEARS TO POSE A POTENTIAL FOR A HIGHER DEGREE OF UNCERTAINTY IN
      ESTABLISHING THE ESTIMATE OF ASSUMED LOSS RESERVES AS COMPARED TO DIRECT
      LOSS RESERVES, PLEASE EXPAND THE DISCLOSURE IN THE CRITICAL ACCOUNTING
      ESTIMATES SECTION OF MD&A RELATED TO THIS UNCERTAINTY. ACCORDINGLY, PLEASE
      REVISE MD&A TO INCLUDE THE FOLLOWING INFORMATION:

      a.    INCLUDE IN THIS DISCLOSURE THE RISKS ASSOCIATED WITH MAKING THIS
            ESTIMATE AND THE EFFECTS AND EXPECTED EFFECTS THIS UNCERTAINTY HAS
            OR WILL HAVE ON MANAGEMENT'S JUDGMENTS AND ASSUMPTIONS IN
            ESTABLISHING THE ASSUMED LOSS RESERVE;

      b.    THE NATURE AND EXTENT OF THE INFORMATION RECEIVED FROM THE CEDANTS
            RELATED TO POLICIES, CLAIMS, UNEARNED PREMIUMS AND LOSS RESERVES;

      c.    THE TIME LAG FROM WHEN CLAIMS ARE REPORTED TO THE CEDANT TO WHEN THE
            CEDANT REPORTS THEM TO THE COMPANY AND WHETHER, HOW, AND TO WHAT
            EXTENT THIS TIME LAG EFFECTS THE LOSS RESERVE
            ESTIMATE;

      d.    HOW MANAGEMENT USES THE INFORMATION RECEIVED FROM THE CEDANTS IN ITS
            DETERMINATION OF ITS ASSUMED LOSS RESERVES, WHETHER REINSURANCE
            INTERMEDIARIES ARE USED TO TRANSACT AND SERVICE REINSURANCE
            POLICIES, AND HOW THAT IMPACTS THE LOSS RESERVING METHODOLOGY;

      e.    THE AMOUNT OF ANY BACKLOG RELATED TO THE PROCESSING OF ASSUMED
            REINSURANCE INFORMATION, WHETHER THE BACKLOG HAS BEEN RESERVED FOR
            IN THE FINANCIAL STATEMENTS AND, IF APPLICABLE, WHEN
            THE BACKLOG WILL BE RESOLVED;

                                       3
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      f.    WHAT PROCESS MANAGEMENT PERFORMS TO DETERMINE THE ACCURACY AND
            COMPLETENESS OF THE INFORMATION RECEIVED FROM THE CEDANTS;

      g.    HOW MANAGEMENT RESOLVES DISPUTES WITH CEDANTS, HOW OFTEN DISPUTES
            OCCUR, AND THE MAGNITUDE OF ANY CURRENT, MATERIAL DISPUTES; AND

      h.    WHETHER MANAGEMENT USES HISTORICAL LOSS INFORMATION TO VALIDATE ITS
            EXISTING RESERVES AND/OR AS A MEANS OF NOTICING UNUSUAL TRENDS IN
            THE INFORMATION RECEIVED FROM THE CEDANTS.

            In response to the comments set forth in this paragraph 3, we have
            included additional disclosure in the excerpt from our 2004 10-K set
            forth in Exhibit B.

4.    WE BELIEVE YOUR DISCLOSURE IN MANAGEMENT'S DISCUSSION AND ANALYSIS
      REGARDING THE RESERVE FOR LOSS AND LOSS ADJUSTMENT EXPENSES COULD BE
      IMPROVED TO BETTER EXPLAIN THE JUDGMENTS AND UNCERTAINTIES SURROUNDING
      THIS ESTIMATE AND THE POTENTIAL IMPACT ON YOUR FINANCIAL STATEMENTS. WE
      BELIEVE THAT DISCLOSURES EXPLAINING THE LIKELIHOOD THAT MATERIALLY
      DIFFERENT AMOUNTS WOULD BE REPORTED UNDER DIFFERENT CONDITIONS OR USING
      DIFFERENT ASSUMPTIONS IS CONSISTENT WITH THE OBJECTIVE OF MANAGEMENT'S
      DISCUSSION AND ANALYSIS. ACCORDINGLY, PLEASE REVISE MD&A TO INCLUDE THE
      FOLLOWING INFORMATION FOR EACH OF YOUR LINES OF BUSINESS:

      a.    PLEASE DISCLOSE THE RESERVES ACCRUED AS OF THE LATEST BALANCE SHEET
            DATE PRESENTED. THE TOTAL OF THESE AMOUNTS SHOULD AGREE TO THE
            AMOUNT PRESENTED ON THE BALANCE SHEET.

            In response to the comment set forth in this paragraph 4.a, we have
            included additional disclosure in the excerpt from our 2004 10-K set
            forth in Exhibit B.

      b.    PLEASE DISCLOSE THE RANGE OF LOSS RESERVE ESTIMATES AS DETERMINED BY
            YOUR ACTUARIES. INCLUDE THE KEY ASSUMPTIONS USED TO ARRIVE AT
            MANAGEMENT'S BEST ESTIMATE OF LOSS RESERVES WITHIN THAT RANGE AND
            WHAT SPECIFIC FACTORS LED MANAGEMENT TO BELIEVE THIS AMOUNT RATHER
            THAN ANY OTHER AMOUNT WITHIN THE RANGE REPRESENTED THE BEST ESTIMATE
            OF INCURRED LOSSES. INCLUDE QUANTIFIED AND NARRATIVE ANALYSES OF THE
            IMPACT THAT REASONABLY LIKELY CHANGES IN ONE OR MORE OF THE
            VARIABLES (I.E. ACTUARIALLY METHOD AND/OR ASSUMPTIONS USED) WOULD
            HAVE ON REPORTED RESULTS, FINANCIAL POSITION AND LIQUIDITY.

            We do not calculate a range around our loss reserves, but we do use
            point estimates. Accordingly, we refer you to our response to
            paragraph 4.c below.

                                       4
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      c.    IF YOU DO NOT CALCULATE A RANGE AROUND YOUR LOSS RESERVE, BUT
            INSTEAD USE POINT ESTIMATES PLEASE INCLUDE THE FOLLOWING
            DISCLOSURES:

            -     DISCLOSE THE VARIOUS METHODS CONSIDERED AND THE METHOD THAT
                  WAS SELECTED TO CALCULATE THE RESERVES. IF MULTIPLE POINT
                  ESTIMATES ARE GENERATED, INCLUDE THE RANGE OF THESE POINT
                  ESTIMATES. INCLUDE A DISCUSSION OF WHY THE METHOD SELECTED WAS
                  MORE APPROPRIATE OVER THE OTHER METHODS.

            -     DISCUSS HOW MANAGEMENT DETERMINED THE MOST APPROPRIATE POINT
                  ESTIMATE AND WHY THE OTHER POINT ESTIMATES WERE NOT CHOSEN.
                  ALSO CLARIFY WHETHER THE COMPANY ACTUALLY RECORDS TO THE POINT
                  ESTIMATE OR IF NOT, HOW THAT ESTIMATE IS USED.

            -     INCLUDE QUANTIFIED AND NARRATIVE DISCLOSURE OF THE IMPACT THAT
                  REASONABLY LIKELY CHANGES IN ONE OR MORE OF THE VARIABLES
                  (I.E. ACTUARIALLY METHOD AND/OR ASSUMPTIONS USED) WOULD HAVE
                  ON REPORTED RESULTS, FINANCIAL POSITION AND LIQUIDITY.

            In response to the comment set forth in this paragraph 4.c, we have
            included additional disclosure in the excerpt from our 2004 10-K set
            forth in Exhibit B.

      d.    BECAUSE IBNR RESERVE ESTIMATES ARE MORE IMPRECISE, PLEASE DISCLOSE
            THE AMOUNT OF IBNR SEPARATELY FROM CASE RESERVES FOR EACH LINE OF
            BUSINESS.

            In response to the comment set forth in this paragraph 4.d, we have
            included additional disclosure in the excerpt from our 2004 10-K set
            forth in Exhibit B.

NOTES TO CONSOLIDATED FINANCIAL STATEMENTS

UNPAID LOSSES AND LAE, PAGES F-17

5.    WE NOTE FROM YOUR DISCLOSURE THAT FAVORABLE DEVELOPMENT OCCURRED DUE TO
      CHANGES IN 2004 OF ESTIMATES OF PREMIUMS AND THE PATTERNS OF THEIR
      EARNINGS ACROSS CURRENT AND PRIOR ACCIDENT YEARS. PLEASE CLARIFY IN YOUR
      FILING HOW CHANGES IN PREMIUMS ESTIMATES IMPACTED THE DEVELOPMENT OF YOUR
      LOSS RESERVES.

            When previous estimates of earned premium are increased or
            decreased, the related provisions for losses and LAE previously
            recorded are also increased or decreased. This disclosure has been
            added to "Critical Accounting Policies -- Premiums" in Exhibit B.

                                       5
<PAGE>
                               *    *    *    *

If you have any questions regarding these responses or any further comments,
please contact the undersigned at (441) 295-7195.

Very truly yours,

/s/ Joseph F. Fisher

Joseph F. Fisher
Executive Vice President
and Chief Financial Officer

Enclosures
Copy (w/encl) to Dana Hartz
                 Joseph Roesler
                 Jeffrey P. Riedler
                 Song Brandon
                 Suzanne Hayes

                                       6
<PAGE>
                                                                      APPENDIX I

                                  UNITED STATES
     (SEC LOGO)         SECURITIES AND EXCHANGE COMMISSION
                             WASHINGTON, D.C. 20549
    DIVISION OF
CORPORATION FINANCE

      MAIL STOP 6010

                                                August 10, 2005

Mr. Joseph F. Fisher
Executive Vice President And Chief Financial Officer
Platinum Underwriters Holdings, Ltd.
The Belvedere Building
69 Pitts Bay Road
Pembroke, Bermuda Hm 08

RE:  PLATINUM UNDERWRITERS FINANCE INC.
     PLATINUM UNDERWRITERS HOLDINGS, LTD.
     REGISTRATION STATEMENT ON FORM S-4
     FILE NUMBER 333-126883

Dear Mr. Fisher:

      This is to advise you that we have limited our review of the above
referenced registration statement to only the issues identified below. 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.

      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.

Form 10-K for the fiscal year ended December 31, 2004

      1.    We will be monitoring the accounting disclosure in the Form 10-K for
            the period ended December 31, 2004 for Platinum Underwriters
            Holdings, Ltd. You will be receiving our accounting comments under
            separate cover. All comments will need to be fully resolved before
            we take final action on the registration statement.

Form S-4

      2.    We refer you to your registration statement on Form S-1
            (No.333-86906) that went effective on October 28, 2002. In that S-1,
            it appears you were offering unit securities

                                        1
<PAGE>
            which included an ownership interest in a senior note of Platinum
            Underwriters Finance, Inc. It is unclear to us why Platinum
            Underwriters Finance has not been filing periodic reports since the
            effectiveness of that Form S-1. Please provide us with an analysis
            as to how you determined Platinum Underwriters Finance was not
            required to file any periodic reports following the effectiveness of
            the Form S-1 referenced above.

General

      3.    We note that you are registering the exchange notes in reliance on
            Staff's position set forth in Exxon Capital Holdings Corporation
            (May 13, l988), Morgan Stanley & Co. Incorporated (June 5, 1991),
            and Shearman & Sterling (July 2, 1993). Accordingly, with your next
            filing, please provide us with a supplemental letter stating you are
            registering the exchange offer in reliance on Staff's position
            contained in the