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April 18, 2024
Stephen Sills
Chief Executive Officer
Bowhead Specialty Holdings Inc.
1411 Broadway, Suite 3800
New York, NY 10018
Re:Bowhead Specialty Holdings Inc.
Registration Statement on Form S-1
Filed April 12, 2024
File No. 333-278653
Dear Stephen Sills:
            We have reviewed your registration statement and have the following comments.
            Please respond to this letter by amending your registration statement and providing the
requested information. If you do not believe a comment applies to your facts and circumstances
or do not believe an amendment is appropriate, please tell us why in your response.
            After reviewing any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments. Unless we noteotherwise,
our references to prior comments are to comments in our February 21, 2024 letter.
Registration Statement on Form S-1
Prospectus Summary
Who We Are, page 1
1.We note your response to prior comment 1 and revised disclosures on pages 47 and
116 that discuss, among other things, the new contractual terms with AmFam. However, it
is unclear how these new contractual terms compare to the current AmFam arrangement
terms that have been in place for the financial statement periods presented. Please revise
your disclosures where applicable to address the items below, or tell us where this
information is already disclosed.
•Provide a more fulsome discussion of the contractual terms and rights between you
and AmFam under your current arrangement, and quantify any related financial
statement impacts for each period presented. Discussion should include, but not be
limited to: fee terms; whether any authority parameters exist; how decisions are
made; details of any termination provisions; and whether there is a right of refusal or

 FirstName LastNameStephen Sills
 Comapany NameBowhead Specialty Holdings Inc.
 April 18, 2024 Page 2
 FirstName LastName
Stephen Sills
Bowhead Specialty Holdings Inc.
April 18, 2024
Page 2
denial by either entity.
•To the extent that your new arrangement terms with AmFam differ from your prior
arrangement, disclose such differences or state that none exist.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Premiums, page 58
2.We note your disclosures on page 58 regarding the drivers of gross written premium
increase from 2022 to 2023. Please expand your disclosures to quantify the impact of each
key driver and to provide some additional detail, such as clarifying the proportion of
volume from existing versus new distribution partners, quantifying "strong" premium
retention rates, and identifying new products and expanded offerings. Refer to Item
303(b)(2) of Regulation S-K.
Reconciliation of Non-GAAP Financial Measures, page 59
3.We note your adjustment to exclude strategic initiative expenses incurred to set up your
Baleen Specialty initiative. Please expand your disclosures to clarify the nature of the
expenses and where they are reflected in your financial statements.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Cara Lubit at 202-551-5909 or Robert Klein at 202-551-3847 if you have
questions regarding comments on the financial statements and related matters. Please contact
Aisha Adegbuyi at 202-551-8754 or Christian Windsor at 202-551-3419 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Dwight S. Yoo, Esq.