SecProbe.io

CORRESP
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filename1.htm

February
24,  2006

VIA FAX

Jim B.
Rosenberg
Senior Assistant Chief Accountant
Division of
Corporate Finance
United States Securities and Exchange
Commission
100 F Street N.E.
Washington D.C.
20549

Our
Ref:

JC040106

Your
Ref:

001-31909

Re:
Aspen
Insurance Holdings Limited (the
"Company")

Review of Form 10-K for
the fiscal Year Ended December  31,  2004 Filed
March  14,  2005

(File No.
001-31909)

Dear Mr.
Rosenberg,

Further to our response letter dated February
2, 2006 and the discussion between me and Ms. Dana Hartz on February
17, 2006, Ms. Hartz noted the Company's expanded disclosure in
relation to the SEC's Comment #2 in the SEC's letter dated
December 20, 2005, but stated that the SEC still believes that the
Company's disclosure on the impact of reasonably likely changes
in one or more variables for our premium estimates on reported results,
financial position and liquidity could be further expanded. Ms. Hartz
also confirmed that the SEC has no follow-up comments on the rest of
our responses in our letter dated February 2, 2006.

We
have set out below our proposed additional response to Comment #2 and
for your convenience, we set forth in this letter (the
"Response Letter") Comment #2 from your
letter dated December 20, 2005, in bold typeface and include the
Company's response below such comment.

Item 7.
Management's Discussion and Analysis of Financial Condition and
Results of Operations

Critical Accounting Policies
– Premiums, page 68

2.
We believe your disclosure in
Management's Discussion and Analysis regarding the estimate of
assumed premium on your reinsurance business could be improved to
better explain the judgments and uncertainties surrounding this
estimate and the potential impact on your financial statements.
Accordingly, please provide us the following information in
disclosure-type format to help us evaluate the adequacy of your
disclosure:

a.
Please
disclose the assumed premium estimate for each line of business,
including the amount of any estimate for commissions and related
expenses and the amount included in premium receivable related to the
estimate.

b.
Discuss
the key assumptions used to arrive at management's best estimate
of the assumed premium estimate and what specific factors led
management to believe that this amount is the most realistic. Please
include quantified and narrative disclosure of the impact that
reasonably likely changes in one or more of the variables (i.e.
methodology and/or assumptions used) would have on reported results,
financial position and liquidity.

c.
Disclose
the provision for doubtful accounts that is recorded related to the
assumed premium estimate. If no provision is recorded, please discuss
why management believes all amounts recorded are collectible.

Following my conversation with Ms. Hartz, it was
established that the additional disclosure should focus on the
Company's treaty pro rata business. In our Annual Report on Form
10-K, we propose to provide the following additional disclosure:

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The reported gross written premiums for
treaty pro rata business includes an estimate of premiums due to the
Company but not yet reported by the cedent because of time delays
between contracts being written by our cedents and the submission of
treaty statements to the Company. This additional premium is normally
described as pipeline premium. Treaty statements disclose information
on the underlying contracts of insurance written by our cedents and are
generally submitted on a monthly or quarterly basis, from 30 to 90 days
in arrears. In order to report all risks incepting prior to a period
end, the Company will estimate the premiums written between the last
submitted treaty statement and the period end.

The segment for
which treaty pro rata is most relevant is our property reinsurance
segment. In connection with our property reinsurance treaty pro rata
business, as of December 31, 2005, we wrote $[168.1] million
in gross written premium, of which $[49.2] million was
estimated, and $[118.9] was reported by the cedents. We
estimate that the impact of a $1 million change in our estimated gross
premiums written in our property treaty pro rata business would have an
impact of $[466,000] on our net income before tax for our
property reinsurance segment.

Thank you for your
consideration of the responses. If you have any further questions or
comments, please contact me at 1-441-297-9371, Michael Groll of
LeBoeuf, Lamb, Greene & MacRae at 1-212-424-8616 or Joe Ferraro of
LeBoeuf, Lamb, Greene & MacRae at 011-44-207-459-5125.

Yours sincerely,

/s/
Julian Cusack
Julian Cusack
Chief Financial Officer
Aspen
Insurance Holdings Limited

Cc:
Dana
Hartz
Lisa Vanjoske
    U.S. Securities and Exchange
Commission

Ian Campbell
David Curtin
Patricia
Roufca
    Aspen Insurance Holdings Limited

Richard
Bennison
Robert Lewis
David Greenfield
    KPMG Audit
Plc

Michael Groll
Joseph Ferraro
    LeBoeuf,
Lamb, Greene & MacRae

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