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SEC Company Response from CRM Holdings, Ltd. (CIK 0001338949) — Dec 16, 2005

CRM Holdings, Ltd. (CIK 0001338949)
Date: Dec. 16, 2005 · CIK: 0001338949 · Accession: 0000950123-05-014871

AI Filing Summary & Sentiment

File numbers found in text: 333-128424

Date
December 16, 2005
Author
Not clearly detected
Form
CORRESP
Company
CRM Holdings, Ltd. (CIK 0001338949)

Letter

Re:

December 16, 2005

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street N.E.

Washington, D.C. 20549

Attention: Mr. Mike McTiernan, Special Counsel

CRM Holdings, Ltd. (the “Company”)

Registration Statement on Form S-1

File No. 333-128424

Ladies and Gentlemen:

On behalf of the Company, request is hereby made that the effective date of the above-captioned Registration Statement be accelerated so that it will become effective on December 20, 2005 at 3:00 P.M. Eastern Time, or as soon thereafter as may be practicable.

In connection with our submission of this request, we acknowledge that:

•

should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

•

the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

•

the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
CRM HOLDINGS, LTD.

Show Raw Text
CORRESP
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filename1.htm

corresp

December 16, 2005

Securities and Exchange Commission

Division of Corporation Finance

100 F. Street N.E.

Washington, D.C. 20549

Attention: Mr. Mike McTiernan, Special Counsel

         Re:

    CRM Holdings, Ltd. (the “Company”)

Registration Statement on Form S-1

File No. 333-128424

Ladies and Gentlemen:

     On behalf of the Company, request is hereby made that the effective date of the
above-captioned Registration Statement be accelerated so that it will become effective on December
20, 2005 at 3:00 P.M. Eastern Time, or as soon thereafter as may be practicable.

     In connection with our submission of this request, we acknowledge that:

    •

    should the Securities and Exchange Commission (the “Commission”) or the staff,
acting pursuant to delegated authority, declare the filing effective, it does not
foreclose the Commission from taking any action with respect to the filing;

    •

    the action of the Commission or the staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the Company from
its full responsibility for the adequacy and accuracy of the disclosure in the
filing; and

    •

    the Company may not assert staff comments and the
declaration of effectiveness as a defense in any proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.

    Very truly yours,

CRM HOLDINGS, LTD.

    By:
    /s/  Daniel G. Hickey, Jr.

    Daniel G. Hickey, Jr.

    Co-Chief Executive Officer

    By:
    /s/  Martin D. Rakoff

    Martin D. Rakoff

    Co-Chief Executive Officer