SecProbe.io

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Mail Stop 6010
Via Facsimile and U.S. Mail

August 30, 2005

Mr. Ramon M. Ruiz-Comas
President and Chief Executive Officer
Triple-S Management Corporation
1441 F. D. Roosevelt Avenue
San Juan, PR 00920

      Re:      Triple-S Management Corporation
       Form 10-K for Fiscal Year Ended December 31, 2004
	            File No. 0-49762

Dear Mr. Ruiz-Comas:

      We have limited our review of your filing to those issues
addressed in our comments.  In our comments, we ask you to provide
us
with information so we may better understand your disclosure.
After
reviewing this information, we may 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 any other aspect
of
our review.  Feel free to call us at the telephone numbers listed
at
the end of this letter.

Exhibit 13.1 - Annual Report

Management`s Discussion and Analysis of Financial Condition and
Results of Operations
Critical Accounting Policies, page 16

1. It appears your discussion does not include an analysis of the
uncertainties in applying these accounting policies or
quantification
of the related variability in operating results that you expect to
be
reasonably likely to occur. This disclosure should provide
investors
with a fuller understanding of the uncertainties in applying
critical
accounting policies and the likelihood those materially different
amounts would be reported under different conditions or using
different assumptions. Please tell us in a disclosure-type format
the
uncertainties in applying these accounting policies, the
historical
accuracy of these critical accounting estimates, a quantification
of
their sensitivity to changes in key assumptions and the expected
likelihood of material changes in the future in order to evaluate
your disclosure.

2. Disclosures explaining the likelihood that materially different
amounts would be reported under different conditions or using
different assumptions are consistent with the objective of
Management`s Discussion and Analysis.  Your disclosure regarding
claim liabilities does not appear to include an adequate
explanation
of the judgments and uncertainties surrounding these estimates and
the potential impact on your financial statements. Accordingly,
please provide us the following information in a disclosure-type
format for each of your lines of business:

* Tell us 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.
* Tell us the range of loss reserve estimates as determined by
your
actuaries.  Discuss 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.
* Provide more precise insight into the existence and effects on
future operations and financial condition of known trends in claim
frequency and severity. Link this discussion to liquidity and
capital
resources.

3. It appears that you have significantly revised your estimates
of
loss reserves recorded in prior years.  We noted that total
reserve
releases in 2003 and 2002 represented approximately 62% and 36% of
net income in each year and that reserve strengthening in first
six
months of 2005 resulted in a net loss for this period. Please
provide
us with the following information in a disclosure-type format by
line
of business:

* Identify the years to which the change in estimate relates and
the
amount of the related loss reserve as of the beginning of the year
that was re-estimated.  Explain to us and quantify offsetting
changes
in estimates that increase and decrease the loss reserve.
Identify the changes in the key assumptions you made to estimate
the
reserve since the last reporting date. *
* Identify the nature and timing of the change in estimate,
explicitly identifying and describing in reasonable specificity
the
new events that occurred or additional information acquired since
the
last reporting date that led to the change in estimate.
* Explain why recognition occurred in the periods that it did and
why
recognition was not required in earlier periods.
* Discuss significant emerging trends in claim frequency and
severity
(e.g. number of claims incurred, average settlement amounts) and
any
other trends, necessary to understand the change in estimate.
Explain
the rationale for a change in estimate that does not correlate
with
these trends.

Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 2. Significant Accounting Policies

Revenue Recognition, page 31

4. Your revenues under self-funded arrangements appear to include
policyholder deposits for funding claims as well as stop loss
premiums and fees for service. Please tell us the nature of
revenues
recognized under these arrangements, summarize premiums by funding
option for each period presented (i.e. fully insured to self-
funded)
and refer us to the technical guidance upon which you base your
revenue accounting for these arrangements.

Note 9. Federal Employees` Health Benefits Program, page 55

5. Your disclosure appears to indicate that FEHBP operates like a
fee-for-service contract under which you bear no insurance risk.
We
note that you recognized contributions of $108.1 million and
underwriting expenses of $107.6 million in 2004 under this
program,
including contributions from a special OPM account that ensures
that
FEHBP operations do not produce an excess or deficiency of revenue
or
expenses. Please clarify the nature of revenues recognized under
this
program and refer us to the technical guidance upon which you
based
your accounting.

*    *    *    *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Your letter
should
key your responses to our comments.  Detailed letters greatly
facilitate our review.  Please file your letter on EDGAR under the
form type label CORRESP.

      We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in your letter, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Frank Wyman, Staff Accountant, at 202-551-
3660
or Don Abbott, Senior Staff Accountant, at 202-551-3608, if you
have
questions regarding the comments.  In this regard, do not hesitate
to
contact me, at (202) 551-3679.

							Sincerely,

							Jim B. Rosenberg
						Senior Assistant Chief Accountant
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Mr. Ramon M. Ruiz-Comas
Triple-S Management Corporation
August 30, 2005
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