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TRIPLE-S MANAGEMENT CORPORATION

September 12, 2005

Via EDGAR

United States Securities and Exchange Commission

Washington, DC 20549

Attention: Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

    Re:

    Triple-S Management Corporation

Form 10-K for Fiscal Year Ended December 31, 2004

File No. 0-49762

Dear Mr. Rosenberg:

We have received your letter dated August 30, 2005 that includes your comments about our Annual
Report on Form 10-K as of December 31, 2004. We appreciate your comments and have attached our
response as Exhibit 1 to this letter. If possible, we would like to implement these changes in the
Annual Report on Form 10-K as of December 31, 2005.

Triple-S Management acknowledges that: the Corporation is responsible for the adequacy and accuracy
of the disclosure in its 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 Federal securities laws of the United States.

If you have any comments please do not hesitate to communicate with me at (787) 749-4949. My fax
number is (787) 749-4091.

Sincerely,

/s/ Ramón M. Ruiz-Comas

Ramón M. Ruiz-Comas

President and Chief Executive Officer

Triple-S Management Corporation

Triple-S Management Corporation

Form 10-K for Fiscal Year Ended December 31, 2004

File No. 0-49762

Exhibit 1

Exhibit 13.1 — Annual Report

Management’s Discussion and Analysis of Financial Condition and Results of Operations

Critical Accounting Policies, page 16

Comment 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 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.

In its Annual Report on Form 10-K as of December 31, 2004, the Corporation disclosed three critical
accounting policies: claim liabilities, impairment of investments and allowance for doubtful
receivables.

Claim Liabilities

Consolidated claim liabilities amounted to $279.3 million as of December 31, 2004; of that total
$127.3 million are related to unreported losses and $14.7 million are related to unpaid
loss-adjustment expenses, both amounts are based on estimates. The remaining balance corresponds
to claims processed and incomplete. Management continually evaluates the potential for changes in
its claim liabilities estimates, both positive and negative, and uses the results of these
evaluations both to adjust recorded claim liabilities and to adjust underwriting criteria. The
Corporation’s profitability depends in large part on accurately predicting and effectively managing
the amount of claims incurred, particularly those of the health insurance segments and the losses
arising from the property and casualty insurance segment. Management regularly reviews its
premiums and benefits structure to reflect the Corporation’s underlying claims experience and
revised actuarial data; however, several factors could adversely affect the Corporation’s
underwriting income. Some of these factors are beyond management control and could adversely
affect its ability to accurately predict and effectively control claims incurred. Examples of such
factors include changes in health practices, economic conditions, change in utilization trends,
healthcare costs, the advent of natural disasters, and malpractice litigation. Costs in excess of
those anticipated could have a material adverse effect on the Corporation’s results of operations.

The Corporation recognizes claim liabilities as follows:

Health Insurance segments

At December 31, 2004, claim liabilities for the Health Insurance segments amounted to $168.9
million and represented 61% of the total consolidated claim liabilities and 27% of the total
consolidated liabilities.

Liabilities for unreported losses are determined employing actuarial methods that are commonly used
by health insurance actuaries and meet Actuarial Standards of Practice. Actuarial Standards of
Practice require that the claim liabilities be adequate under moderately adverse circumstances.
The segment determines the amount of the liability for unreported losses by following a detailed
actuarial process that entails using both historical claim payment

1

Triple-S Management Corporation

Form 10-K for Fiscal Year Ended December 31, 2004

File No. 0-49762

Exhibit 1

patterns as well as emerging
medical cost trends to project a best estimate of claim liabilities. Under this process,
historical data of paid claims is formatted into claim triangles which compare claim incurred dates
to the dates of claim payments. This information is analyzed to create “completion (or
development) factors” that represent the average percentage of total incurred claims that have been
paid through a given date after being incurred. Completion factors are applied to claims paid
through the financial statement date to estimate the ultimate claim expense incurred for the
current period. Actuarial estimates of claim liabilities are then determined by subtracting the
actual paid claims from the estimate of the total expected claims incurred.

The majority of claims unpaid are related to the most recent incurred months. Since the percentage
of claims paid for claims incurred in those months is generally very low, the completion factor
methodology is less reliable for such months. Therefore, historical completion and payment
patterns are applied to incurred and paid claims for the most recent twelve months and each prior
twelve month period. Incurred claims for the most recent twelve months are also projected by
estimating the claims expense for those months based on recent claims expense levels and health
care trend levels, or “trend factors”.

Because the reserve methodology is based upon historical information, it must be adjusted for known
or suspected operational and environmental changes. These adjustments are made by the actuaries
based on their knowledge and their estimate of emerging impacts to benefit costs and payment speed.
Circumstances to be considered in developing our best estimate of reserves include changes in
utilization levels, unit costs, mix of business, benefit plan designs, provider reimbursement
levels, processing system conversions and changes, claim inventory levels, regulatory and
legislative requirements, claim processing patterns and claim submission patterns. A comparison of
prior period liabilities to re-estimated claim liabilities based on subsequent claims development
is also considered in making the liability determination. In the actuarial process, the methods
and assumptions are not changed as reserves are recalculated, but rather the availability of
additional paid claims information drives our changes in the re-estimate of the unpaid claim
liability. To the extent appropriate, changes in such development are recorded as a change to
current period benefit expense. The re-estimates or recasts are done monthly for the previous four
calendar quarters.

Management regularly reviews its assumptions regarding the claim liabilities and makes adjustments
to claims incurred when necessary. If it is determined that management’s assumptions regarding
cost trends and utilization are significantly different than actual results, our statement of
earnings and financial position could be impacted in future periods. Changes of prior year
estimates may result in an increase in claims incurred or a reduction of claims incurred in the
period the change is made. Further, due to the considerable variability of health care costs,
adjustments to claims liabilities occur each quarter and are sometimes significant as compared to
the net income recorded in that quarter. Prior year development of claim liabilities is recognized
immediately upon the actuary’s judgment that a portion of the prior year liability is no longer
needed or that an additional liability should have been accrued.

As described above, the completion factors and trend factors can have a significant impact on the
claim liabilities. The following example provides the estimated impact to our December 31, 2004
claim liabilities assuming hypothetical changes in the completion and trend factors:

2

Triple-S Management Corporation

Form 10-K for Fiscal Year Ended December 31, 2004

File No. 0-49762

Exhibit 1

(dollar amounts in millions)

    Completion Factor 1

    Claims Trend Factor 2

    (Decrease) Increase

    (Decrease) Increase

    in Completion

    In Unpaid Claim

    in Claims Trend

    In Unpaid Claim

    Factor

    Liabilities

    Factor

    Liabilities

    -0.6%

-0.4%

-0.2%

0.2%

0.4%

0.6%

    $6.7

4.4

2.2

(2.2)

(4.4)

(6.7)

    -0.6%

-0.4%

-0.2%

2.0%

0.4%

0.6%

    $5.4

3.6

1.8

(1.8)

(3.6)

(5.4)

    1

    Assumes (decrease) increase in the completion factors for the most recent twelve months.

    2

    Assumes (decrease) increase in the claims trend factors for the most recent twelve months.

The segments reserving practice is to consistently recognize the actuarial best estimate as the
ultimate liability for claims within a level of confidence required by actuarial standards. Thus,
only when the release of a prior year reserve is not offset with the same level of conservatism in
estimating the current year reserve, will the redundancy create a net reduction in current benefit
expense. The opposite is true for any claim liabilities shortfalls. Management believes that the
methodology in determining the best estimate for claim liabilities at each reporting date has been
consistently applied.

Amounts incurred related to prior years vary from previously estimated liabilities as the claims
are ultimately settled. Liabilities at any year end are continually reviewed and re-estimated as
information regarding actual claims payments, or run-out, becomes known. This information is
compared to the originally established year end liability. Negative amounts reported for incurred
claims related to prior years result from claims being settled for amounts less than originally
estimated. The reverse is true of reserve shortfalls. Medical claim liabilities are usually
described as having a “short tail”, which means that they are generally paid within several months
of the member receiving service from the provider. Accordingly, the majority, or approximately
95%, of any redundancy or shortfall relates to claims incurred in the previous calendar year-end,
with the remaining 5% related to claims incurred prior to the previous calendar year-end. Two
major events have affected the segments claim payment patterns — a slowdown in claims submissions
from providers due to HIPAA coding changes that occurred during the later half of 2003 and the
effect of tropical storm Jeanne, which limited access to providers during the months of September
and October 2004. The first event affects historical completion factors while the second event
changed utilization trends.

The following table shows the variance between the segments’ total incurred claims as reported and
the incurred claims for such years had it been determined retrospectively (computed as the
difference between “Incurred claims related to current period insured events” for the year shown
and the “Incurred claims related to prior period insured events” for the immediately following
year). This table shows that the segments’ estimates of this liability have approximated the
actual development.

3

Triple-S Management Corporation

Form 10-K for Fiscal Year Ended December 31, 2004

File No. 0-49762

Exhibit 1

    (dollar amount in millions)

    2003

    2002

    Total incurred claims:

    As reported

    $
    1,026.0

    1,032.2

    On a retrospective basis

    1,030.0

    1,018.7

    Variance

    $
    (4.0
    )

    13.5

    Variance to total incurred claims as reported

    -0.4
    %

    1.3
    %

Management expects that substantially all of the development of the 2004 estimate of medical claims
payable will be known during 2005 and that the variance of the total incurred claims a
retrospective basis when compared to reported incurred claims will be similar to the prior year.

Property and Casualty Insurance segment

At December 31, 2004, claim liabilities for the Property and Casualty Insurance segment amounted to
$89.6 million and represented 32% of the total consolidated claim liabilities and 14% of the total
consolidated liabilities.

Estimating the ultimate cost of claims and loss-adjustment expenses of this segment is an uncertain
and complex process. This estimation process is based largely on the assumption that past
developments, with appropriate adjustments due to known or unexpected changes, are a reasonable
base in which to predict future events and trends, and involves a variety of actuarial techniques
that analyze current experience, trends and other relevant factors. Property and casualty
insurance claim liabilities are categorized and tracked by “line of business”, such as commercial
multi-peril package business, property, auto physical damage, auto liability, general liability and
medical malpractice. Medical malpractice policies are written on a claims-made basis. Policies
written on a claims-made basis require that claims be reported during the policy period. Other
lines of business are written on an occurrence basis.

Individual case estimates for reported claims are established by a claims adjuster and are changed
as new information becomes available during the course of handling the claim. Our property and
casualty business, other than medical malpractice, is primarily short-tailed business, where losses
(e.g. paid losses and case reserves) generally emerge (i.e. are reported) quickly.

Claim reserve reviews are generally conducted on a quarterly basis, in light of continually updated
information, and include participation of our independent actuaries. Our actuaries review reserves
for both current and prior accident years using current claims data. These reviews incorporate a
variety of actuarial methods, judgments, and analysis. For each line of business, a variety of
actuarial methods are used, with the final selections of ultimate losses that are appropriate for
each line of business selected based on the current circumstances affecting that line of business.
These selections incorporate input from claims personnel, underwriting and operating management of
reported loss cost trends and other factors that could affect the reserve estimates.

Key assumptions are based on the consideration that past emergence of paid losses and case reserves
is credible and likely indicative of future emergence and ultimate losses. A key assumption is the
expected loss ratio for the current accident year. This expected loss ratio is generally
determined through a review of the loss ratios of prior accident years and expected changes to
earned pricing, loss costs, mix of business, and other factors that are expected to impact the loss
ratio for the current accident year. Another key assumption is the development patterns for paid
and reported losses (also referred to as the loss emergence and settlement patterns). The reserves
for unreported claims for each year are determined after reviewing the indications produced b