SecProbe.io

March 5 , 2014

Via E -mail
Douglas N. Raucy
President and Chief Executive Officer
1347 Property Insurance Holdings, Inc.
9100 Bluebonnet Centre Blvd., Suite 502
Baton Rouge, LA 70809

Re: 1347 Property Insurance Holdings, Inc.
Amendment No. 2 to Registration Statement on Form S -1
Filed February 25 , 2014
  File No. 333 -193314

Dear Mr. Raucy :

We have reviewed your amended registration statement  and have the following additional
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 this letter by amending your registration statement again and providing
the re quested information .  If you do not believe our comments apply to your facts and
circumstances or do not believe an other  amendment is appropriate, please tell us why in your
response.

After reviewing any further amendment to your registration statement and the
information you provide in response to these  comments, we may have  additional comments.

General

1. Please explain to us when you expect the 1,000: 1 stock split to be completed and how
you plan to address i nconsistencies between shares and per share amounts presented in
your Capitalization and Dilution disclosure and the corresponding amounts presented in
your historical financial statements.

Capitalization, page 33

2. Please revise your disclosure to presen t a pro forma column which includes the items you
identified in (i) and ii) in the headnote to your tabular disclosure and then a pro forma as
adjusted column which would include the above items and the issuance of shares in this
offering.

Douglas N. Raucy
1347 Property Insurance Holdings, Inc.
March 5 , 2014
Page 2

 Dilution, page  34

3. You have not disclosed a net tangible book value per share before the planned offering
that is consistent with historical amounts shown in your consolidated balance sheet at
December 31, 2013. Please explain to us your basis for concluding that this p resentation
of dilution per share to new investors conforms to guidance in Item 506 of Regulation
S-K.

Notes to Consolidated Financial Statements
1. Description of the Company and Summary of Significant Accounting Policies
Significant Accounting Policies , page F -9

4. Please explain why you omitted the disclosure, “Recently Issued Accounting Standards.”

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   Since the company and its management are in
possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disc losures they have made.

Notwithstanding our comments, in the event you request acceleration of the effective date
of the pending regist ration statement please provide  a written statement from the company
acknowledging that:

 should 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.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date  of the registration statement as confirmation
of the fact that those requesting acceleration are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offe ring of the securities specified in the above registration statement.  Please allow
adequate time  for us to review any amendment prior to the requested effective date of the
registration statement.

Douglas N. Raucy
1347 Property Insurance Holdings, Inc.
March 5 , 2014
Page 3

 You may contact Frank Wyman at (202) 551 -3660 or Joe l Parker at (202) 551 -3651 if
you have questions regarding comments on the financial statements and related matters. Please
contact Scot Foley at (202) 551 -3383 or me at (202) 551 -3715 with any other questions.

Sincerely,

       /s/ Daniel  Greenspan for

Jeffrey P. Riedler
Assistant Director

cc:  Joel L. Rubinstein, Esq.
Eric Orsic, Esq.
McDermott Will & Emery LLP
340 Madison Avenue
New York, New York 10173