SecProbe.io

October 31, 2013

Via E-mail
Mr. John Worth
Chief Financial  Officer
Aspen Insurance Holding Limited
141 Front Street
Hamilton, Bermuda
HM 19

 Re: Aspen Insurance Holding Limited
  Form 10-K for the Year Ended December 31 , 2012
  Filed February  26, 201 3
File No.  001-31909

Dear M r. Worth :

We have limited our review  to only your financial statements and related disclosures and
do not intend to expand our review to other portions of your documents.  In our comment s, we
ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 business days by providing the requested
information or by advising us when you will provide the requested response.  If you do not
believe a comment applies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the form type label CORRESP that keys your
responses to our comments.

After reviewing the information you provide, we may have additional comments and/or
request that you amend your filing.

Notes to the Audited Consolidated Financial Statements

Note 2. Basis of Preparation and Significant Accounting Policies
(b) Accounting for Insurance and Reinsurance Operations
Policy Acquisition Expenses, page F -12

1. Please provide us revised disclosure to be included in futur e periodi c reports that
addresses  the following requirements of ASC 944 -30-50-1:
• Please revise your policy disclosure to clarify that the nature of acquisition costs
capitalized relates only to the costs associated with successful efforts;
• Disclose the a mount of acquisition cost amortized for the period ; and

Mr. John Worth
Aspen Insurance Holding Lim ited
October 31, 2013
Page 2

 • Clarify whether the policy acquisition expenses line -item on your statements of
operations and comprehensive income include s expenses that are not capitalized and
amortized.

Note 11. Income Taxes, page F -42

2. Please provide us proposed disclosure to be included in future periodic reports that
addresses the following issues related to disclosure in your income tax rate reconciliation
table on page F -43:
 Please explain the significant prior year adjust ments relative to expected tax
benefit/expense in 2012 and 2010.  Please separately tell us why these adjustments
were recorded in the periods they were and why they are not indicative of errors in
your previous period financial statements.
 Please separate ly disclose each of the reconciling items that represent greater than 5%
of your expected income tax benefit/expense as required by Item 4 -08(h)(2) of
Regulation S -X.  In this regard, the absolute value of your “other” reconciling item is
approximately 53%  of the expected tax benefit in 2012.
To extent necessary to understanding the changes in your effective income tax
benefit/expense for each period presented, please also provide revised MD&A disclosure,
as applicable, to be included in future periodic rep orts.

Note 18. Commitments and Contingencies
(d) Contingencies, page F -61

3. On page 76 you state that you do not believe that the eventual outcome of any specific
litigation, arbitration or alternative dispute resolution proceedings to which you are
curren tly a party will have a material adverse effect on the financial condition of your
business as a whole.   Please provide us proposed disclosure to be included in future
periodic reports that discusses your assessment of materiality on your results of
operat ions and cash flows taking into consideration the courts motion for partial summary
judgment against the company for $42 million in 2011. In addition, please revise your
disclosure to address the required disclosures of ASC 450 -20-50.

 We urge all persons  who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing include s all information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.  Since the company and its manageme nt 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 responding t o our comment s, please provide  a written statement from the company
acknowledging  that:

 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

Mr. John Worth
Aspen Insurance Holding Lim ited
October 31, 2013
Page 3

  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.

You may contact Sasha Parikh, Staff Accountant, at  (202) 551 -3627 or Mark Brunhofer ,
Revi ew Accountant, at (202) 551 -3638  if you have questions regarding the comments. In this
regard, do not hesitate to contact me at (202) 551 -3679.

Sincerely,

/s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chief  Accountant