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CORRESP
 1
 filename1.htm

 CORRESP

 American Integrity Insurance Group, Inc.
 5426 Bay Center Drive, Suite 600
 Tampa, FL 33609 VIA EDGAR SUBMISSION
 November 17, 2025 United States Securities and Exchange
Commission Division of Corporation Finance Office of
Finance 100 F Street, N.E. Washington, D.C. 20549

 Attention:
 Aisha Adegbuyi

  
 Christian Windsor

 Re:
 American Integrity Insurance Group, Inc.
 Registration Statement on Form S-1
 Registration File No. 333-291588
 Ladies and Gentlemen: In accordance with Rule
461 under the Securities Act of 1933, American Integrity Insurance Group, Inc. (the “Registrant”) hereby requests that the effective date for the Registration Statement referred to above (the “Registration Statement”) be
accelerated so that it will become effective at 4:45 p.m., Eastern Time, on November 19, 2025, or as soon thereafter as is practicable, or at such other time as the Registrant or the Registrant’s legal counsel, Haynes and Boone, LLP,
requests by telephone that such Registration Statement be declared effective. The Registrant hereby authorizes Matthew L. Fry and Michael
Haden, of Haynes and Boone, LLP, to orally modify or withdraw this request for acceleration. Please contact Matthew L. Fry at (214) 651-5443 or, in his absence, Michael Haden at (214) 651-5162, both of Haynes and Boone, LLP, the Registrant’s legal counsel, when the Registration Statement has been
declared effective or if you have any other questions or concerns regarding this matter. Thank you in advance for your assistance.
 * * * * *

 Very truly yours,

 AMERICAN INTEGRITY INSURANCE GROUP, INC.

 By:

 /s/ Robert Ritchie

 Name:

 Robert Ritchie

 Title:

 Chief Executive Officer

 cc:
 Matthew L. Fry, Esq., Haynes and Boone, LLP
 Michael Haden, Esq., Haynes and Boone, LLP
 Dwight S. Yoo, Esq., Skadden, Arps, Slate, Meagher & Flom LLP
 Ryan J. Dzierniejko, Esq., Skadden, Arps, Slate, Meagher & Flom LLP
 Michael P. Reed, Esq., Skadden, Arps, Slate, Meagher & Flom LLP

CORRESP
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 filename1.htm

 CORRESP

 November 17, 2025
 VIA EDGAR

 Attention:
 Aisha Adegbuyi

  
 Christian Windsor
 Securities and Exchange Commission Division of Corporation
Finance 100 F Street, N.E. Washington D.C. 20549

 Re:
 American Integrity Insurance Group, Inc.

  
 Acceleration Request for American Integrity Insurance Group, Inc.

  
 Registration Statement on Form S-1

  
 File No. 333-291588
 Ladies and Gentlemen: Pursuant to
Rule 460 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as amended, please be advised that there has been distributed or will be distributed to each underwriter or dealer who is
reasonably anticipated to participate in the distribution of the security as many copies of the Company’s preliminary prospectus dated November 17, 2025 as appears to be reasonable to secure adequate distribution of the preliminary
prospectus. We, the undersigned Representatives, have been informed by the participating underwriters that they will comply with the
requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection with the proposed offering.
 In accordance with Rule 461 of the Securities Act, we hereby join in the request of the registrant that the effectiveness of the
above-captioned Registration Statement, as amended, be accelerated to 4:30 p.m., Eastern Time, on November 19, 2025, or at such later time as the registrant’s counsel may orally request via telephone call to the staff of the Division
of Corporation Finance of the Securities and Exchange Commission. [Signature Page Follows]

 Very truly yours,

 KEEFE, BRUYETTE & WOODS, INC.
 PIPER SANDLER & CO.
 As representatives of the several underwriters
 KEEFE, BRUYETTE & WOODS, INC.

 By:

 /s/ Wesley Fox

 Name:

 Wesley Fox

 Title:

 Managing Director

 PIPER SANDLER & CO.

 By:

 /s/ Demetrios S. Hadgis

 Name:

 Demetrios S. Hadgis

 Title:

 Managing Director
 [Signature Page to Acceleration Request]

CORRESP
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 CORRESP

 American Integrity Insurance Group, Inc.
 5426 Bay Center Drive, Suite 600
 Tampa, FL 33609 VIA EDGAR SUBMISSION
 May 5, 2025 United States Securities and Exchange
Commission Division of Corporation Finance Office of
Finance 100 F Street, N.E. Washington, D.C. 20549

 Attention:
 Aisha Adegbuyi

  
 Christian Windsor

 Re:
 American Integrity Insurance Group, Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Registration File No. 333-286524
 Ladies and Gentlemen: In accordance with Rule
461 under the Securities Act of 1933, American Integrity Insurance Group, Inc. (the “Registrant”) hereby requests that the effective date for the Registration Statement referred to above (the “Registration Statement”) be
accelerated so that it will become effective at 4:00 p.m., Eastern Time, on May 7, 2025, or as soon thereafter as is practicable, or at such other time as the Registrant or the Registrant’s legal counsel, Haynes and Boone, LLP, requests by
telephone that such Registration Statement be declared effective. The Registrant hereby authorizes Matthew L. Fry and Logan J. Weissler,
of Haynes and Boone, LLP, to orally modify or withdraw this request for acceleration. Please contact Matthew L. Fry at (214) 651-5443 or, in his absence, Logan J. Weissler at (214) 651-5813, both of Haynes and Boone, LLP, the Registrant’s legal counsel, when the Registration Statement has been
declared effective or if you have any other questions or concerns regarding this matter. Thank you in advance for your assistance.
 * * * * *

 Very truly yours,

 AMERICAN INTEGRITY INSURANCE GROUP, INC.

 By:

 /s/ Robert Ritchie

 Name:

 Robert Ritchie

 Title:

 Chief Executive Officer

 cc:
 Matthew L. Fry, Esq., Haynes and Boone, LLP
 Logan J. Weissler, Esq., Haynes and Boone, LLP
 Dwight S. Yoo, Esq., Skadden, Arps, Slate, Meagher & Flom LLP
 Ryan J. Dzierniejko, Esq., Skadden, Arps, Slate, Meagher & Flom LLP
 Michael P. Reed, Esq., Skadden, Arps, Slate, Meagher & Flom LLP

CORRESP
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 CORRESP

    May 5, 2025
 VIA EDGAR

 Attention:

 Aisha Adegbuyi

 Christian Windsor

 Securities and Exchange Commission
 Division of Corporation Finance 100 F Street, N.E.
 Washington D.C. 20549

 Re:
 American Integrity Insurance Group, Inc.
 Acceleration Request for American Integrity Insurance Group, Inc.
 Registration Statement on Form S-1
 File No. 333-286524 Ladies and Gentlemen:
 Pursuant to Rule 460 of the General Rules and Regulations of the Securities and Exchange Commission under the Securities Act of 1933, as
amended, please be advised that there has been distributed or will be distributed to each underwriter or dealer who is reasonably anticipated to participate in the distribution of the security as many copies of the Company’s preliminary
prospectus dated April 29, 2025 as appears to be reasonable to secure adequate distribution of the preliminary prospectus. We, the
undersigned Representatives, have been informed by the participating underwriters that they will comply with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended, in connection
with the proposed offering. In accordance with Rule 461 of the Securities Act, we hereby join in the request of the registrant that the
effectiveness of the above-captioned Registration Statement, as amended, be accelerated to 4:00 p.m., Eastern Time, on May 7, 2025, or at such later time as the registrant’s counsel may orally request via telephone call to the staff of the
Division of Corporation Finance of the Securities and Exchange Commission. [Signature Page Follows]

 Very truly yours,

 KEEFE, BRUYETTE & WOODS, INC.

 PIPER SANDLER & CO.

 As representatives of the several underwriters

 KEEFE, BRUYETTE & WOODS, INC.

 By:

 /s/ Wesley Fox

 Name:

 Wesley Fox

 Title:

 Managing Director

 PIPER SANDLER & CO.

 By:

 /s/ Demetrios Hadgis

 Name:

 Demetrios Hadgis

 Title:

 Managing Director
 [Signature Page to Acceleration Request]

CORRESP
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 CORRESP

 April 14, 2025
 VIA EDGAR U.S. Securities and Exchange
Commission 100 F Street, N.E. Division of Corporation
Finance Office of Finance Washington, D.C. 20549
 Attention: Aisha Adegbuyi, Amit Pande, Michael Volley and Christian Windsor

 Re:

 American Integrity Insurance Group, Inc.
 Amendment No. 1 to Draft Registration Statement on Form S-1
 Submitted March 25, 2025 CIK
No. 0002007587
 Ladies and Gentlemen:
 On behalf of American Integrity Insurance Group, LLC (to be converted into American Integrity Insurance Group, Inc.) (the “Company”),
below is the response of the Company to the comments of the staff of the Division of Corporation Finance (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”) set forth in the Staff’s
letter, dated April 9, 2025, regarding Amendment No.1 to the Company’s Draft Registration Statement on Form S-1 as confidentially submitted with the Commission on March 25, 2025.
Concurrently with the submission of this letter, the Company is publicly filing a Registration Statement on Form S-1 (the “Registration Statement”) in response to the Staff’s comments and to
reflect certain other changes. For your convenience, the Staff’s comments are set forth in bold, followed by responses on behalf of
the Company. Unless otherwise indicated, all page references in the responses set forth below are to the pages of the clean copy of the Registration Statement. Capitalized terms used but not otherwise defined herein shall have the meanings assigned
to such terms the Registration Statement. Amendment No.1 Draft Registration Statement on Form S-1
 Prospectus Summary Selectively assume policies from
Citizens, page 10

 1.
 We note your response to prior comment 4. Please quantify the costs associated with assuming Citizen’s
policies. Based on your revised disclosure, please consider revising your risk factors if appropriate.
 Response : The Company acknowledges the Staff’s comment and respectfully advises the Staff that costs associated with assuming
Citizen’s policies are limited to time spent by a small number of the Company’s employees to select policies that meet the Company’s criteria and are not material.

 Management’s Discussion and Analysis of Financial Condition and Results of Operations
 Revenues, page 59

 2.
 We note your disclosure that for the year ended December 31, 2024, gross premiums written and policies
in-force increased significantly primarily driven by the strategic expansion of your Citizens take-out program and higher policy retention rates. Please revise to present a summary table that shows a
rollforward of your policies-in-force by source (e.g., Citizens, organic originations, acquisitions, etc.) for each of the periods presented.
 Response : The Company acknowledges the Staff’s comment and has revised the disclosure on page 62 of the Registration Statement
accordingly. Industry Florida Homeowners
Insurance Market, page 78

 3.
 We note your disclosure on page 81 that, “generally, policyholders can choose to optout unless the
premium offered is within 20% of what Citizens charges, in which case the take-out is required to be accepted by the insured.” Please revise to clarify if the premium offered is for the renewal or current
premium. Response : The Company acknowledges the Staff’s comment and has revised the disclosure on page
84 of the Registration Statement accordingly. Business, page 84

 4.
 We note your response to prior comment 13. Given your dependence on certain third-parties and service
providers, please revise your disclosure, if applicable, to specify how significantly your business would be impacted if they were to terminate the business relations. Please revise your Risk Factors and MD&A sections accordingly.
 Response : The Company acknowledges the Staff’s comment and respectfully advise the Staff that the
Company is not materially dependent on any third-party or service provider with respect to its key products or product lines and that the Company believes it would be able to replace any such third-party or service provider expeditiously and on
commercially reasonable terms should any such business relationship terminate. Reinsurance and Risk Transfer, page 102

 5.
 We note your response to prior comment 3. We also note your reference to predicted losses under the AIR
model. We also note that the “modeled PML” for storms predicted only $33.4 million from losses from Hurricane Andrew. Please discuss the extent that the AIR model takes into account potential

increases in costs due to the effects of inflation and increased development density on the AIR model and your expected net retention.
 Response : The Company acknowledges the Staff’s comment and has revised the disclosure on page 107 of the Registration
Statement accordingly. Additionally, we respectfully advise the Staff that the low loss figure from Hurricane Andrew is due to the small number of Company policies currently in-force in the areas of Florida
primarily affected by Hurricane Andrew. Notes to Consolidated Financial Statements
 Citizens Assumed Reinsurance, page F-31

 6.
 Please revise the “Effect of Reinsurance” table to breakout the premiums written and earned
between amounts assumed and amounts from voluntary markets. Response : The Company acknowledges the
Staff’s comment and has revised the “Effects of Reinsurance” table on page F-32 of the Registration Statement accordingly.
 Note 10. Regulatory Requirements and Restrictions, page F-32

 7.
 Please revise to disclose the amount of statutory capital and surplus, or similar solvency measure, and the
amount necessary to satisfy regulatory requirements if significant in relation to the insurance entity’s statutory capital and surplus for Catstyle. Refer to ASC 944-505-50-1 for guidance. Response : The Company acknowledges
the Staff’s comment and has revised the disclosure on pages F-33 to F-34 of the Registration Statement to clarify the capital and surplus and collateral
requirements of Catstyle accordingly. *  *  *  *  *  *

 If you have any questions or require any additional information in connection with the
filing, please do not hesitate to contact the undersigned at (214) 651-5443.

 Very truly yours,

 /s/ Matthew L. Fry

 Matthew L. Fry

 Haynes and Boone

 cc:

 Matthew L. Fry, Esq., Haynes and Boone, LLP

 Logan J. Weissler, Esq., Haynes and Boone, LLP

 Dwight S. Yoo, Esq., Skadden, Arps, Slate, Meagher & Flom LLP

 Ryan J. Dzierniejko, Esq., Skadden, Arps, Slate, Meagher & Flom LLP

 Michael P. Reed, Esq., Skadden, Arps, Slate, Meagher & Flom LLP

 Robert Ritchie, Chief Executive Officer of American Integrity Insurance Group, LLC

<DOCUMENT>
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<TEXT>
 April 9, 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.
 Amendment No. 1 to Draft Registration Statement on Form S-1
 Submitted March 25, 2025
 CIK No. 0002007587
Dear Robert Ritchie:

 We have reviewed your amended 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. Unless we note otherwise, any references to prior comments are to
comments in
our March 10, 2025 letter.

Amendment No. 1 to Draft Registration Statement on Form S-1
Prospectus Summary
Selectively assume policies from Citizens, page 10

1. We note your response to prior comment 4. Please quantify the costs
associated with
 assuming Citizen's policies. Based on your revised disclosure, please
consider revising
 your risk factors if appropriate.
 April 9, 2025
Page 2
Management's Discussion and Analysis of Financial Condition and Results of
Operations
Revenues, page 59

2. We note your disclosure that for the year ended December 31, 2024, gross
premiums
 written and policies in-force increased significantly primarily driven
by the strategic
 expansion of your Citizens take-out program and higher policy retention
rates. Please
 revise to present a summary table that shows a rollforward of your
policies-in-force
 by source (e.g., Citizens, organic originations, acquisitions, etc.) for
each of the
 periods presented.
Industry
Florida Homeowners Insurance Market, page 78

3. We note your disclosure on page 81 that, generally, policyholders can
choose to opt-
 out unless the premium offered is within 20% of what Citizens charges,
in which case
 the take-out is required to be accepted by the insured. Please revise
to clarify if the
 premium offered is for the renewal or current premium.
Business, page 84

4. We note your response to prior comment 13. Given your dependence on
certain third-
 parties and service providers, please revise your disclosure, if
applicable, to specify
 how significantly your business would be impacted if they were to
terminate the
 business relations. Please revise your Risk Factors and MD&A sections
accordingly.
Reinsurance and Risk Transfer, page 102

5. We note your response to prior comment 3. We also note your reference to
predicted
 losses under the AIR model. We also note that the "modeled PML" for
storms
 predicted only $33.4 million from losses from Hurricane Andrew. Please
discus the
 extent that the AIR model takes into account potential increases in
costs due to the
 effects of inflation and increased development density on the AIR model
and your
 expected net retention.
Notes to Consolidated Financial Statements
Citizens Assumed Reinsurance, page F-31

6. Please revise the Effect of Reinsurance table to breakout the
premiums written and
 earned between amounts assumed and amounts from voluntary markets.
Note 10. Regulatory Requirements and Restrictions, page F-32

7. Please revise to disclose the amount of statutory capital and surplus,
or similar
 solvency measure, and the amount necessary to satisfy regulatory
requirements if
 significant in relation to the insurance entity s statutory capital
and surplus for
 Catstyle. Refer to ASC 944-505-50-1 for guidance.
 April 9, 2025
Page 3

 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.
</TEXT>
</DOCUMENT>

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<TEXT>
 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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