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CORRESP

 Trean Insurance Group, Inc.

150 Lake Street West

Wayzata, MN 55391

 August 19, 2021

 Via EDGAR Transmission and E-mail

 U.S.
Securities and Exchange Commission

 Division of Corporation Finance, Office of Finance

100 F Street, N.E.

 Washington, D.C. 20549

Attention: Michael Volley

 Amit Pande

Re:
 Trean Insurance Group, Inc. (the “Registrant”)

Form 10-K for the Fiscal Year Ended December 31, 2020

Filed March 26, 2021

File No. 001-39392

 Gentlemen:

We hereby submit the Registrant’s response to the comments of the Staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) that were conveyed in a letter to the Registrant dated July 22, 2021, in connection with the Staff’s review of the Registrant’s Annual Report on Form 10-K for the fiscal year ended
December 31, 2020. For your convenience, we have reproduced the Staff’s comments in bold preceding our responses.

 Form 10-K for the
Fiscal Year Ended December 31, 2020

 Item 1. Business, page 6

1.
 Please revise future filings to more clearly compare and contrast the economics, revenue model, reinsurance
strategies and other key characteristics between business with Program Partners and Owned MGA’s. For example, explain if one is generally more profitable than the other, the magnitude of fees in the profitability of each, if and how the revenue
and profitability profile may change as the Program Partner relationship matures, the extent and type of reinsurance used for each, etc.

Response:

 We will revise our future 10-K
filings to more clearly compare and contrast the economics and other key characteristics between business with Program Partners and Owned MGAs. We will also include information related to the revenues associated with Program Partners and Owned

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MGAs as well as other key characteristics and material trends, as applicable. An example of these additional disclosures related to fiscal 2020 follows.

Example disclosure

The following table shows the total premiums earned on a gross and net basis for Owned MGAs and Program Partners:

Year Ended December 31, 2020

Owned MGAs

Program Partner

Total

 Gross written premiums

$
285,622

$
198,627

$
484,249

 Increase in gross unearned premiums

(7,552
)

(44,663
)

(52,215
)

 Gross earned premiums

278,070

153,964

432,034

 Ceded earned premiums

(204,676
)

(118,891
)

(323,567
)

 Net earned premiums

$
73,394

$
35,073

$
108,467

 Both Owned MGAs and Program Partners utilize quota share and catastrophe XOL contracts in their reinsurance
strategy. For the year ended December 31, 2020, the Company retained 26.4% of gross earned premiums for Owned MGAs compared to 22.8% for Program Partners. The loss ratios for Owned MGAs and Program Partners for the year ended December 31,
2020 were 52.2% and 35.5%, respectively, resulting in a consolidated loss ratio of 46.8%. The lower loss ratio for Program Partners was primarily attributable to favorable developments on certain large Program Partners during the period.

The ceding commission rate, net of direct commissions, for the year ended December 31, 2020, for Owned MGAs was 13.6% compared to 8.6% for
Program Partners. The lower ceding commission rate for Program Partners was driven primarily by MGA fees paid to Program Partners or third-party MGAs on premiums, whereas the services for Owned MGAs are performed by the Company and are included in
operating expenses within general and administrative expenses in the consolidated statement of operations.

 Issuing carrier services, page 12

2.
 Please revise future filings to quantify the revenue from issuing carrier services for each period presented
and disclose where they are presented in the income statement.

 Response:

Please note that reinsurance brokerage fees are not “issuing carrier services” but a separate service performed in conjunction with
issuing carrier services. Reinsurance brokerage services are separately described and disclosed under the heading “Reinsurance brokerage services” beginning on page 12 of our Annual Report on Form 10-K, where total reinsurance brokerage
fees are quantified by period. In future 10-K filings we will disclose that reinsurance brokerage fees are recorded within ‘Other revenue’ in the consolidated statement of operations.

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 The fees we receive associated with issuing carrier services primarily consist of reinsurance
ceding commissions received from our Program Partners and/or third-party reinsurers. One component of the reinsurance ceding commissions are fronting fees which are not separately billed or contracted for but are included as part of the reinsurance
ceding commissions rate we charge our reinsurers. Reinsurance ceding commissions are recognized as a reduction of our direct insurance commission expense within “General and administrative expenses” in the consolidated statement of
operations.

 In future 10-K filings, we will modify our description of issuing carrier services to distinguish these reinsurance ceding
commissions from reinsurance brokerage fees. An example of our modified disclosure follows. Disclosures added in our modified disclosure are underlined and disclosures removed are struck out from our modified disclosure.

Issuing carrier services

 We
provide issuing carrier or “fronting” services to several of our Program Partners who distribute offer workers’ compensation, commercial multi-peril, personal auto, and
commercial auto and other liability insurance business. In these relationships, we act as the policy-issuing insurance carrier for our Program Partner and transfer all or a substantial portion of the underwriting risk to
third-party reinsurers. Unlike some other issuing carrier models, we typically act as the reinsurance broker to the program as well as the issuing carrier, which we believe enables us to have deeper relationships with our Program Partners as
well as earn additional revenue for the placement of reinsurance. When we enter into issuing carrier relationships, we receive fronting fees reinsurance ceding commissions at rates that include our fronting service
from our reinsurers who are both Program Partners and/or third-party reinsurers and reinsurance brokerage fees and reinsurance ceding commissions from our reinsurance partners. Fronting fees Reinsurance ceding commissions
vary based on the line of business and premium volume. We provide issuing carrier services across each of our insurance products. We provide issuing carrier services to some of our Program Partners that offer workers’ compensation or
other liability insurance. For the years ended December 31, 2020, 2019 and 2018, reinsurance ceding commissions from issuing carrier services were $71.8 million, $87.7 million and $76.6 million, respectively, and are recognized as a
reduction of direct insurance commission expense within ‘General and administrative expenses’ in the consolidated statement of operations.

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 4

 Reinsurance, page 15

3.
 Please revise future filings to discuss the magnitude of each type of reinsurance used (i.e. quota share and
catastrophe XOL) including the impact of each type on your financial results.

 Response:

Although on page 15 of our Annual Report on Form 10-K we describe the two major types of reinsurance contracts we generally utilize to manage
risk—namely, quota share and Catastrophe XOL reinsurance—we do not manage our business or the impacts on our financial results by reinsurance contract type. We utilize a variety of reinsurance arrangements in conjunction, to manage an
overall risk of loss level that aligns with our current financial objectives, capital base, A.M. Best financial strength rating, and our risk appetite. Additionally, as noted in the first paragraph of the “Reinsurance” section on page 15,
“the cost and limits of the reinsurance coverage we purchase vary from year to year based on the availability of quality reinsurance at an acceptable price and our desired level of retention.” As such, our historical financial results
reflect a mix of varying reinsurance arrangements and retention levels spanning several years. Because of this, we currently do not bifurcate our financial results by contract type nor do we have the ability to do so without extraordinary effort. In
addition to being at odds with how our business is managed, presenting our results in this bifurcated manner would necessarily entail a highly extensive and complex disclosure that we believe would have the potential to create confusion and would
not be reflective of expected future performance based on our current reinsurance strategy. The tabular summary on page 16 of our Annual Report on Form 10-K provides the reader with the overall magnitude and our level of retention by reinsurance
type for our core worker’s compensation reinsurance program.

 In future 10-K filings, we will revise the Reinsurance section to
present our two major types of reinsurance contracts as the tools utilized in the Company’s overall risk management strategy as opposed to two distinct measures of financial performance. An example of our modified disclosure follows.
Disclosures added in our modified disclosure are underlined and disclosures removed are struck out from our modified disclosure.

 Reinsurance

 We cede a portion of the risk we accept on our balance sheet to third-party reinsurers through a variety of reinsurance
arrangements. We manage these arrangements to align risks with our Program Partners, optimize our net retention relative to our financial objectives, balance sheet size and ratings requirements, as well as to limit our maximum loss resulting from a
single program or a single event. We utilize both quota share and excess of loss (“XOL”) reinsurance as tools in our overall risk management strategy to achieve these goals, usually in conjunction with each other. Quota share
reinsurance involves the proportional sharing of premiums and losses of each defined program. We utilize quota share reinsurance for several purposes,

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including (i) to cede risk to Program Partners, which allows us to share economics and align incentives and (ii) to cede risk to third-party reinsurers in order to manage our net
written premiums appropriately based on our financial objectives, capital base, A.M. Best financial strength rating and risk appetite. It is a core pillar of our underwriting philosophy that Program Partners retain a portion of the underwriting risk
of their program. We believe this best aligns interests, attracts higher quality programs and leads to better underwriting results. Under XOL reinsurance, losses in excess of a retention level are paid by the reinsurer, subject to a limit, and
are customized per program or across multiple programs. We utilize XOL reinsurance to protect against catastrophic or other unforeseen extreme loss activity that could otherwise negatively impact our profitability and capital base. The majority
of our exposure to catastrophic risk stems from the workers’ compensation premium we retain. Potential catastrophic events include an earthquake, terrorism or another event that could cause more than one covered employee working at the same
location to be injured in the event. We believe we mitigate this risk by our focus on small- to mid-sized accounts, which means that we generally do not have concentrated employee counts at single locations that could be exposed to a catastrophic
loss. The cost and limits of the reinsurance coverage we purchase vary from year to year based on the availability of quality reinsurance at an acceptable price and our desired level of retention.

Quota share reinsurance

We utilize quota share reinsurance for several purposes, including (i) to cede risk to Program Partners, which allows us to share
economics and align incentives and (ii) to cede risk to third-party reinsurers in order to manage our net written premiums appropriately based on our financial objectives, capital base, A.M. Best financial strength rating and risk appetite. It
is a core pillar of our underwriting philosophy that Program Partners retain a portion of the underwriting risk of their program. We believe this best aligns interests, attracts higher quality programs and leads to better underwriting
results.

 Catastrophe XOL reinsurance

We have designed an XOL reinsurance program to protect against catastrophic or other unforeseen extreme loss activity that could
otherwise negatively impact our profitability and capital base. The majority of our exposure to catastrophe risk stems from the workers’ compensation premium we retain. Potential catastrophic events include an earthquake, terrorism or another
event that could cause more than one covered employee working at the same location to be injured in the event. We believe we mitigate this risk by our focus on small- to mid-sized accounts, which means that we generally do not have concentrated
employee counts at single locations that could be exposed to a catastrophic loss.

 Investments, page 19

4.
 We note your disclosure that as of December 31, 2020, you had $174.7 million of funds held under
reinsurance treaties, that these funds are held in separate accounts for the benefit of your Program Partners, and that the funds withheld assets and associated investment in-come belong to your various Program Partners. Please revise future filings
to disclose

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which party manages the investments. Also, please tell us how you considered whether this arrangement resulted in an embedded derivative. Refer to guidance in ASC 815-15-55-107. If you have an
embedded derivative, please revise future filings to disclose how you account for it and provide appropriate information for investors to understand its impact on your financial reporting. For example, disclose:

•

 the value of the embedded derivative at each period end,

•

 how you measure the embedded derivative and where you present it in your balance sheet and income
statement, and

•

 the information required by ASC 820-10-50 and ASC 815-10-50.

Response:

 In future 10-K filings, we
will disclose that the Company manages the funds withheld investments.

 Upon further reflection and in consideration of the guidance in ASC
815-15-55-107, we identified certain errors in our previously issued financial statements associated with the recording and presentation of embedded derivatives. These errors have been determined to not be material; however, these errors were
corrected during in our Quarterly Report on Form 10-Q for the period ended June 30, 2021 (the “Second Quarter Form 10-Q”), as described below.

The Company has determined that it will report the change in fair value of the embedded derivatives in gains (losses) on embedded derivatives
in the condensed consolidated and condensed combined statements of operations, in accordance with ASC 815-15-55-108. The change in fair value was previously reported in accumulated other comprehensive income (loss). In addition, investment earnings
credited to the funds withheld accounts (i.e., realized and unrealized gains (losses) of the embedded derivatives) will be reported in gains (losses) on embedded derivatives in the condensed consolidated and condensed combined statements of
operations. Previously, those amounts were reported as an offset to net investment income. The Company believes the revised presentation aligns with 815-10-45, and the views of the Office of the Chief Accountant at the SEC shared in 2003 with the
AICPA SEC Regulations Committee. No changes to the Funds held under reinsurance agreements line item on the Condensed Consolidated Balance Sheets were