SecProbe.io

December 20, 2017
Scott Kirk
Chief Financial Officer
Aspen Insurance Holdings Ltd.
141 Front Street
Hamilton, HM 19
Bermuda
Re:Aspen Insurance Holdings Ltd.
Form 10-K for Fiscal year ended December 31, 2016
Filed February 22, 2017
File No. 001-31909
Dear Mr. Kirk:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comments.  In some of our comments, we may ask you to
provide us with information so we may better understand your disclosure.
            Please respond to these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the year ended December 31, 2016
Notes to the Audited Consolidated Financial Statements
5. Segment Reporting , page F-18
1.Please tell us whether you aggregate operating segments within each of your two
reporting segments. If so, describe each operating segment within each reporting segment
that is aggregated and how you met each of the criteria in ASC 280-10-50-11. If not,
please explain to us what your disclosure means with respect to the "Company has
considered similarities in economic characteristics, products, customers, distribution, the
regulatory environment of the Company’s business segments and quantitative thresholds
to determine the Company’s reportable segments."

 FirstName LastNameScott Kirk
 Comapany NameAspen Insurance Holdings Ltd.
 June 16, 2017 Page 2
 FirstName LastName
Scott Kirk
Aspen Insurance Holdings Ltd.
December 20, 2017
Page 2
12. Reserves for Losses and Loss Adjustment Expenses, page F-41
2.We see from disclosure in your Form 8-K filed on December 6, 2017 that you provide
loss triangles on your website in a much more disaggregated form and for more accident
years than you presented herein. Please tell us why, and address the following:
•With regard to the tables herein of information about claims development by accident
year, why you concluded that five years of information was sufficient when it appears
that claims incurred typically remain outstanding for more than five years.  Refer to
ASC 944-40-50-4B. If you were relying on impracticability as discussed in ASC 944-
40-65-1.d. to limit the years presented to five, please advise.
•Why you did not disaggregate the tables of incurred claims and paid claims further
into, for example, the lines of business you present on pages 9 and 11 of Form 10-
K. In this regard, we are concerned that the tables may be aggregating lines with
significantly different characteristics. Refer to ASC 944-40-50-4H. For each of the
lines, provide us analysis of the characteristics to support your aggregation. If a line
includes multiple lines such as with "property and casualty insurance" within the
insurance segment, provide the analysis for each line. In your response provide us the
individual tables by line, if available, or to the extent not available , provide us
quantitative data by line such as claims payout period, incurred loss, claims paid and
development per line for each of the last three years .
            In closing, we remind you that the company and its management are responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or
absence of action by the staff.
            You may contact Lisa Vanjoske at 202-551-3614 or Jim Rosenberg at 202-551-3679
with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance