SecProbe.io

Via Facsimile and U.S. Mail Mail Stop 6010                                                                                                   November 16, 2007   Mr. Richard Houghton  Chief Financial Officer Aspen Insurance Holdings Ltd  Maxwell Roberts Building 1 Church Street Hamilton, Bermuda  HM11
Re: Aspen Insurance Holdings Ltd.
 Form 10-K for the Year Ended December 31, 2006  Filed February 22, 2007  File No. 001-31909

Dear Mr. Houghton:

We have reviewed your filing and have the following comments. In our
comments, we ask you to provide us with  information to better understand your
disclosure. Where a comment requests you to  revise disclosure, the information you
provide should show us what the revised disc losure will look like and identify the annual
or quarterly filing, as appli cable, in which you intend to fi rst include it.  If you do not
believe that revised disclosure  is necessary, explain the reason in your response.  After
reviewing the information provided, we may raise additional comments and/or request
that you amend your filing.   Please understand that the purpose of our re view 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.
 General

1. Please provide us your analysis as to how you have determined you are a “foreign
private issuer” under Rule 3b-4(c).

Mr. Richard Houghton
Aspen Insurance Holdings Ltd November 16, 2007 Page 2
 Item 1 Business, page 3

 Underwriting, Risk Management and Reinsurance, page 13

 Reserves, page 19

2. You indicate that you considered a point estimate determined by an independent
consulting actuary.  This reference suggest s to an investor that you are placing
reliance on the firm.  Please include the na me of the valuation firm in the ’34 Act
filing.  Additionally, if the Form 10-K is incorporated by reference into a ’33 Act
registration statement, a consent from the valuation specialist must be provided in
the ’33 Act registration statement.

Item 9A Controls and Procedures, page 104
3. Your disclose that “the Chief Executive Officer and Chief Financial Officer have
concluded that the Company’s disclosure controls and procedures were effective
in ensuring that information required to  be disclosed by the Company in this
report is recorded, processed, summarized  and reported in a timely fashion.”
Please tell us and disclose whether your  officers concluded th at your disclosure
controls and procedures are also effectiv e to ensure that information required to
be disclosed in the reports that you fi le or submit under the Exchange Act is
accumulated and communicated to your management, including your chief
executive officer and chief financial officer, to allow timely decisions regarding
required disclosure.  See Exchange Act Rules 13a-15(e) and 15d-15(e).

*    *    *    *
Please respond to these comments within  10 business days or tell us when you
will provide us with a response.  Please furnish a letter that  keys your responses to our
comments and provide the requested information.  Detailed letters gr eatly facilitate our
review.  Please furnish 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 in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment decision.  Since the company and its
management are in possession of all facts re lating 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 co mments, please provide, in your letter, a
statement from the company acknowledging that:

Mr. Richard Houghton
Aspen Insurance Holdings Ltd November 16, 2007 Page 3
 • the company is responsible for the adequacy  and accuracy of the disclosure in the
filing;
• 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 comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

In addition, please be advise d that the Division of Enfo rcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comment on your filing.
You may contact Ibolya Igna t, Staff Accountant at ( 202) 551-3656, or Mary Mast,
Senior Staff Accountant, at  (202) 551-3613 if you have que stions regarding comments on
the financial statements and related matte rs.  You may contact Sonia Barros, Staff
Attorney, at (202) 551-3655 regard ing other comments.  In this regard, do not hesitate to
contact me, at (202) 551-3679.

Sincerely,

Jim B. Rosenberg Senior Assistant Chief Accountant