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 March 10, 2025

Robert Ritchie
Chief Executive Officer
American Integrity Insurance Group, Inc.
5426 Bay Center Drive, Suite 600
Tampa, FL 33609

 Re: American Integrity Insurance Group, Inc.
 Draft Registration Statement on Form S-1
 Submitted February 10, 2025
 CIK No. 0002007587
Dear Robert Ritchie:

 We have reviewed your draft registration statement and have the
following comments.

 Please respond to this letter by providing the requested information and
either
submitting an amended draft registration statement or publicly filing your
registration
statement on EDGAR. 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 the information you provide in response to this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments.

Draft Registration Statement on Form S-1
Commonly Used Defined Terms, page ii

1. Please revise your definition of Citizens to clarify, if true, that
Citizens is a not-for-
 profit government entity.
Prospectus Summary
Our Competitive Strengths
Sophisticated risk transfer program with high-quality third-party reinsurers,
page 7

2. We note your disclosure regarding your relationships with your
reinsurers, all of
 whom have a financial strength rating of 'A-' or better by A.M. Best .
Please include a
 risk factor addressing any risks to your business associated with your
reinsurers
 receiving a downgrade from A.M. Best or advise.
 March 10, 2025
Page 2

Continue to purchase conservative third-party catastrophe reinsurance coverage,
page 9

3. We note your disclosure in several places throughout your Prospectus
that you "have
 historically sought to buy to the 130-year return period." Please revise
your
 disclosure, where appropriate, to explain what this means for reader
clarity.
Selectively assume policies from Citizens, page 10

4. We note your disclosure that you participated in four take-out
opportunities in 2024
 and assumed 68,884 policies. We also note that you are considering
assuming policies
 from Citizens. Please revise your disclosure to include more details
about the policies
 you assumed in 2024 and please disclose the potential costs associated
with assuming
 Citizen's policies. Based on your revised disclosure please consider
revising your risk
 factors, if appropriate.
Corporate Structure, page 12

5. Please revise your organizational charts on pages 13 and 19 to clarify
the existing
 owners.
Actual claims incurred have exceeded, and in the future may exceed, reserves
established for
claims, page 29

6. We note your disclosure regarding "the adverse conditions in Florida and
inflationary
 pressure causing increases in the costs of building materials and
labor." Please revise
 here to specify the adverse conditions, including examples of how
inflation or other
 conditions have impacted your insured losses above your estimates when
the policies
 were written.
Our results may fluctuate based on cyclical changes in the insurance industry,
page 31

7. Please clarify in this risk factor, and its subheading, where the
insurance industry
 currently is in terms of its cyclical nature so that investors may
assess the risk.
 Specifically, discuss whether the insurance industry is in a hard or
soft market, clearly
 explain what those terms mean, and discuss any effects the current
market has on your
 business.
Risks Related to Our Organizational Structure, page 45

8. Revise this section to discuss the potential anti-takeover effect of the
Tax Receivable
 Agreement, including the potential impact on a merger that may be
beneficial to the
 Class A shareholders.
We have assets held at financial institutions that may exceed the insurance
coverage offered
by the Federal Deposit Insurance Corporation, page 45

9. Revise this risk factor to disclose the aggregate amount of deposits at
banks that
 exceed the FDIC deposit insurance threshold, if material.
 March 10, 2025
Page 3
Management's Discussion and Analysis of Financial Condition and Results of
Operations,
page 78

10. We note that you write insurance coverage for condominiums. We also note
that,
 following the 2021 Surfside Condominium collapse, the Florida
legislature required
 inspections and remediation of buildings that showed signs of structural
integrity
 issues or damage to the building's concrete. Discuss the extent to which
you may be
 required to cover losses in the event of a structural failure, if
material, and discuss the
 extent to which management has evaluated the potential impact on your
market.
 Consider revising your risk factor disclosure based on your response.
Key Business Metrics and Non-GAAP Financial Measures, page 85

11. We note you refer to your adjusted net income (loss) non-GAAP financial
measure
 also as adjusted operating income (loss). Please revise to use a
consistent title
 throughout your filing.
Critical Accounting Policies and Estimates
Impairment, page 97

12. Please revise to ensure your investment impairment accounting policies
in this section
 are consistent with your summary of significant accounting policies on
page F-11
 which appear to be updated for your adoption of ASU 2016-13.
Business, page 105

13. We note your disclosure that you rely on a number of third-party
brokers, service
 providers and catastrophe claim adjuster services. If you depend on key
particular
 third-parties or other service providers that would significantly impact
your business
 if they were to terminate the business relation key products or product
lines, please
 revise your Business, Risk Factors and MD&A sections accordingly.
14. We note your reference to legislative reforms in Florida that were
enacted in 2022.
 Revise your disclosure to discuss the nature of these changes and how
they impacted
 your willingness to purchase policies originally underwritten by
Citizens. Please also
 consider revising your disclosure to clarify whether Management believes
that the
 changes may lead to increased competition from other insurers who might
be incented
 to reenter or expand their Florida insurance offerings.
Competition, page 128

15. We note your disclosure that you face competition from insurers
including Tower Hill
 Insurance Group, Florida Peninsula Insurance Company, Frontline
Insurance
 Unlimited Company, Southern Oak Insurance Company and Progressive.
Please
 provide the criteria you used to identify these companies as your
competitors.
Ratings, page 128

16. We note your risk factor disclosure on page 35 that you do not have a
rating from AM
 Best Company. Revise your disclosure on page 96 to include a similar
discussion.
 March 10, 2025
Page 4
Exclusive Forum, page 164

17. We note that your forum selection provision identifies the Court of
Chancery of the
 State of Delaware as the exclusive forum for certain litigation,
including any
 derivative action Given that this provision applies to Securities
Act and Exchange
 Act claims, please revise this provision, similar to your discussion on
page 55, to state
 that there is uncertainty as to whether a court would enforce such a
provision and that
 investors cannot waive compliance with the federal securities laws and
the rules and
 regulations thereunder.
Change in Independent Auditor, page 185

18. Please tell us if you consulted with Thomas Howell Ferguson P.A. on any
matters
 described in Items 304(a)(2)(i) or 304(a)(2)(ii) of Regulation S-K prior
to engaging
 the accountant in 2024. Please revise your disclosures as necessary.
Please ensure
 your letter to Thomas Howell Ferguson P.A. required by Item 304(a)(3) of
Regulation
 S-K includes any revised disclosure.
Investments
Fixed Maturity Securities, page F-11

19. We note your disclosure that, If these criteria are not met, the
security is not deemed
 to have a zero expected credit loss upon default, or the severity of the
decline in fair
 value is greater than or equal to 80%, the Company will evaluate whether
any
 impairment is attributable to credit-related factors. Please tell us
how the criteria
 related to the 80% severity is relevant, applied to your investments,
and consistent
 with ASC 326 considering that it appears that all securities would be
subject to credit-
 related factors or impairment recognized in earnings absent this
criteria. Please revise
 your disclosures as necessary.
Reinsurance, page F-14

20. Noting that reinsurance recoverables totaled $325 million at December
31, 2023,
 please revise to clarify why you believe the amount of exposure to
reinsurance
 recoverables is not material.
Note 3. Variable Interest Entity, page F-20

21. We note disclosure that appears to indicate that Catstyle is owned by
Artex but also
 that AIIG is the sole shareholder. Please tell us how you determined
that Catstyle was
 owned by Artex considering that AIIG is the sole shareholder. Please
revise your
 disclosure as necessary.
22. Please revise to disclose the information required by ASC
810-10-50-3.bb.
Note 10. Regulatory Requirements and Restrictions, page F-32

23. Please revise to disclose the amount of statutory capital and surplus
necessary to
 satisfy regulatory requirements if significant in relation to the
insurance entity s
 statutory capital and surplus. Refer to ASC 944-505-50-1 for guidance.
24. Please revise to disclose the amount of retained earnings that is not
available for
 payment of dividends. Refer to ASC 944-505-50-1 for guidance.
 March 10, 2025
Page 5

Note 12. Members' Equity and Temporary Members' Equity, page F-34

25. Please tell us why Class B and C units appear to be measured at $0 in
the December
 31, 2023 balance sheet. Please revise your disclosure as necessary.
Note 16. Income Taxes, page F-36

26. Please tell us where the impact of income related to partnerships and
other pass-
 through entities not subject to income tax is presented in the
effective income tax rate
 reconciliation on page F-37. Please revise your disclosure as necessary.
 Please contact Michael Volley at 202-551-3437 or Amit Pande at
202-551-3423 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: Matthew L. Fry, Esq.
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