SEC Company Response from ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395) (AHL-PD) — Jan 18, 2005

ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395)
Date: Jan. 18, 2005 · CIK: 0001267395 · Accession: 0000950136-05-000213

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AI Filing Summary & Sentiment

Sentiment

Urgency

Document Type

Confidence

SEC Posture

Company Posture

Summary

Reasoning

Date

January 13, 2005

Author

Aspen Insurance Holdings Limited

Form

CORRESP

Company

ASPEN INSURANCE HOLDINGS LTD (AHL, AHL-PD, AHL-PE, AHL-PF) (CIK 0001267395)

Letter

RE: ASPEN INSURANCE HOLDINGS LIMITED REGISTRATION STATEMENT ON FORM F-4

[GRAPHIC OMITTED]

ASPEN INSURANCE HOLDINGS LIMITED

Securities and Exchange Commission Division of Corporation Finance 450 Fifth Street, N.W. Washington, D.C. 20549

January 13, 2005

Ladies and Gentlemen:

Aspen Insurance Holdings Limited (the "Issuer") has filed the above referenced Registration Statement on Form F-4 (the "Registration Statement") with the Securities and Exchange Commission on January 13, 2005. The Registration Statement will be used in connection with the exchange of up to $250,000,000 of the Issuer's 6.00% Senior Notes Due 2014, issued on August 16, 2004 (the "Outstanding Notes") which were issued in a transaction which was exempt from registration under the Securities Act of 1933, as amended (the "Securities Act") for the Issuer's 6.00% Senior Notes Due 2014 which are intended to be registered under the Securities Act.

Enclosed with this transmittal letter, please find a supplemental letter which includes certain representations of the Issuer relating to the above described exchange.

Very truly yours,
Aspen Insurance Holdings Limited

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CORRESP
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                                [GRAPHIC OMITTED]

                        ASPEN INSURANCE HOLDINGS LIMITED

Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

                                                                January 13, 2005

RE:     ASPEN INSURANCE HOLDINGS LIMITED
        REGISTRATION STATEMENT ON FORM F-4

Ladies and Gentlemen:

        Aspen Insurance Holdings Limited (the "Issuer") has filed the above
referenced Registration Statement on Form F-4 (the "Registration Statement")
with the Securities and Exchange Commission on January 13, 2005. The
Registration Statement will be used in connection with the exchange of up to
$250,000,000 of the Issuer's 6.00% Senior Notes Due 2014, issued on August 16,
2004 (the "Outstanding Notes") which were issued in a transaction which was
exempt from registration under the Securities Act of 1933, as amended (the
"Securities Act") for the Issuer's 6.00% Senior Notes Due 2014 which are
intended to be registered under the Securities Act.

        Enclosed with this transmittal letter, please find a supplemental letter
which includes certain representations of the Issuer relating to the above
described exchange.

Very truly yours,

Aspen Insurance Holdings Limited

By: /s/ Julian Cusack
    -----------------
    Julian Cusack
    Chief Financial Officer

                        Aspen Insurance Holdings Limited
                                  Victoria Hall
                               11 Victoria Street
                             Hamilton HM 11, Bermuda
                      Tel: 441-295-8201 * Fax: 441-295-1829
                                  www.aspen.bm

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