EGEverest Group

We note that you provided more expansive disclosure in your 2021 Corporate Social Responsibility Report and 2022 Corporate Responsibility Report Supplemental Disclosures (together, the “CSR Reports”) than you provided in your SEC filings. Please advise us what consideration you gave to providing the same type of climate-related disclosure in your SEC filings as you provided in your CSR Reports.

The Company advises the Staff that its CSR Reports are intended to allow stakeholders, including investors, customers, counterparties and vendors, to become aware of the Company’s activities related to ESG matters. As such, disclosures in the CSR Reports are intended to address a range of issues of

Everest Group, Ltd. (“Everest”) is a leading global provider of reinsurance and insurance, operating for close to 50 years through subsidiaries in the U.S., Europe, Singapore, Canada, Bermuda, and other territories.

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Everest offers property, casualty, and specialty products through its various operating affiliates located in key markets around the world. Everest common stock (NYSE: EG) is a component of the S&P 500 index. Additional information about Everest, our people, and our products can be found on our website at www.everestglobal.com. All issuing companies may not do business in all jurisdictions.

varying degrees of importance to a broad set of stakeholders. However, the Company does not consider this information to be “material,” i.e., information that a reasonable shareholder would consider important in making an investment or voting decision, except for information from these reports already incorporated into the Company’s SEC filings. The Company’s periodic filings with the Commission, such as its Form 10-K, include the ESG-related information that is required by the Securities Exchange Act of 1934, as amended (the “Exchange Act”), and the rules and regulations promulgated thereunder, including the disclosure requirements of Regulation S-K. The Company’s periodic reports also include any additional disclosures that, though otherwise not required, are necessary to make other statements by the Company materially accurate or not misleading. The Company believes the disclosures included in its Form 10-K and other SEC filings are appropriate and complete in light of requirements to use a standard of materiality to investors in determining the content of periodic disclosures.

For these reasons, and as further discussed throughout the remainder of this letter, the Company believes that additional climate change-related disclosure is not required to be included in its SEC filings and that including such disclosure could potentially be misleading to investors. Going forward, the Company will, as it has in the past, evaluate whether it is appropriate to include information from its CSR Reports in its SEC filings based on the disclosure requirements applicable at the time of the filing and its assessment of whether the information is material to investors.

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To the extent material, discuss the indirect consequences of climate-related regulation or business trends, such as the following: • decreased demand for products or services that produce significant greenhouse gas emissions or are related to carbon-based energy sources; • increased demand for products or services that result in lower emissions than competing products; • increased competition to develop innovative

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new products that result in lower emissions; • increased demand for generation and transmission of energy from alternative energy sources; and • any anticipated reputational risks resulting from operations or products that produce material greenhouse gas emissions.

The Company advises the Staff that none of the trends identified in the Staff’s comment have been or are material to Everest. Everest’s core business is to provide insurance and reinsurance protection against loss across a broad range of risks in many different sectors of the global economy. Accordingly, changes in demand for or risks from products that produce greenhouse gas emissions or competition in the development of clean or cleaner energy have no direct impacts on Everest’s business, and indirect impacts can be positive, negative or neutral.

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As discussed on pages 26-27 of the Company’s Form 10-K, the demand for property and casualty insurance and reinsurance products is influenced by external factors, such as underwriting results of insurers and insureds, including catastrophe losses, and prevailing general economic conditions. Further, as described on page 18 of the Form 10-K, competition in the types of reinsurance and insurance underwritten by Everest is based on many factors, including the perceived overall financial strength of the reinsurer or insurer, ratings of the reinsurer or insurer by A.M. Best and/or Standard & Poor’s, underwriting expertise, the jurisdictions where the reinsurer or insurer is licensed or otherwise authorized, capacity and coverages offered, premiums charged, other terms and

Everest Group, Ltd. (“Everest”) is a leading global provider of reinsurance and insurance, operating for close to 50 years through subsidiaries in the U.S., Europe, Singapore, Canada, Bermuda, and other territories. Everest offers property, casualty, and specialty products through its various operating affiliates located in key markets around the world. Everest common stock (NYSE: EG) is a component of the S&P 500 index. Additional information about Everest, our people, and our products can be found on our website at www.everestglobal.com. All issuing companies may not do business in all jurisdictions.

conditions of the reinsurance and insurance business offered, services offered, speed of claims payment and reputation and experience in lines written. While climate-related regulation and business trends may have some impact on the risks covered by Everest’s products and services and the prices thereof, those impacts are not material.

In addition, as of the date of this letter, the Company does not anticipate any reputational risk related to emissions from the operations of Everest. For example, the Company undertook a greenhouse gas (“GHG”) emissions inventory project in 2021 for Everest’s U.S. operations, including engaging an independent third party to help collect and monitor its GHG emissions data. As a result of this inventory project, the Company does not believe that Everest’s operations or services produce material GHG emissions and thus does not anticipate there to be any significant reputational risk related to GHG emissions.

For all of the reasons discussed above, the Company believes that neither climate-related regulation nor business trends have materially impacted Everest’s business, financial condition or results of operations.

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We note disclosure in your Form 10-K that climate change may increase the frequency and severity of natural catastrophes and the resulting losses in the future and impact your risk modeling assumptions. We further note disclosure in your Proxy Statement filed April 14, 2023, that insured losses due to extreme weather events are increasing over time, and as climate change worsens, these losses will continue to grow.

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Please discuss the physical effects of climate change on your operations and results. This disclosure may include the following: • severity of weather, such as floods, hurricanes, sea levels, arability of farmland, extreme fires, and water availability and quality; • quantification of material weather-related damages to your property or operations; • potential for indirect weather-related impacts that have affected or may affect your major customers or insured locations; and • any weather-related impacts on the cost or availability of (re)insurance. Include quantitative information for each of the periods covered by your Form 10-K and explain whether increased amounts are expected in future periods.

Everest’s core business is to provide insurance and reinsurance protection against loss across a broad range of risks in many different sectors of the global economy, and to conduct derivative investment activity. Since most of the Company’s assets are intangible, it has experienced no material physical effects of climate change. The potential consequences to Everest arising out of the physical effects of climate change relate principally to losses that are covered by policies issued by Everest.

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They are not related to changes in demand for or risks from products that produce greater or lower greenhouse gas emissions or competition in the development of products that produce or result in clean or cleaner energy, which could have positive, negative or neutral impacts on the Company’s or Everest’s business, financial condition or results of operations.

To control the risks of impacts of losses covered by its issued policies, Everest closely monitors and plans for a broad array of risks, including climate and other environmental risks identified as part of its Enterprise Risk Management (“ERM”) process, which are analyzed and considered during the 10-K preparation and review process. The annual 10-K review process includes review of information provided by the Chief Risk Officer, General Counsel, Segment Financial Officers, Head of Tax, Chief Reserving

Everest Group, Ltd. (“Everest”) is a leading global provider of reinsurance and insurance, operating for close to 50 years through subsidiaries in the U.S., Europe, Singapore, Canada, Bermuda, and other territories. Everest offers property, casualty, and specialty products through its various operating affiliates located in key markets around the world. Everest common stock (NYSE: EG) is a component of the S&P 500 index. Additional information about Everest, our people, and our products can be found on our website at www.everestglobal.com. All issuing companies may not do business in all jurisdictions.

Actuary, and Chief Accounting Officer. A final review is performed by the Chief Executive Officer and Chief Financial Officer. Additionally, a discussion and analysis of key terms impacting the 10-K disclosure is performed as part of the disclosure committee meeting attended by the Chief Accounting Officer, Chief Internal Audit Officer, General Counsel, Chief Executive Officer and Chief Financial Officer, and discussions with members and various committees of the Company’s Board of Directors. Everest employs a data-driven approach to reviewing these risks in all aspects of our business, from modeling to actuarial and underwriting. Climate change is an inherent component of adjustments to Everest’s models, which use meteorological data and statistical analysis along with proprietary claims, loss information, catastrophe models and traditional actuarial analysis. Everest’s pricing and exposure models strive to quantify the impacts of climate change to better allow us to price the risk products we sell and how we deploy our risk capital. In addition, Everest is expanding its risk portfolios to provide insurance and reinsurance protection for renewable energy programs and environmentally sound private and public construction projects.

Severity of weather, such as floods, hurricanes, sea levels, arability of farmland, extreme fires, and water availability and quality

The severity of weather events has increased the likelihood of loss and the severity of the damage caused by such weather events. The top four risk zones in the Company’s catastrophe loss projections are earthquakes in California and winds in the Southeastern United States, Europe and Texas. Everest manages its exposure by limiting its aggregate catastrophe loss exposure in any particular geographic zone and contiguous zones, as well as diversifying its risk portfolio by geographic area and by types and classes of business. Everest has also sought to de-risk its exposure to wind risk, particularly in the Southeastern United States.

Quantification of material weather-related damages to your property or operations

Everest has not experienced any material weather-related damage to its property or operations. Everest’s offices are predominantly located in areas that have been less susceptible to climate change or severe weather-related impacts. Further, the Company’s operations can generally be performed remotely, if necessary.

Potential for indirect weather-related impacts that have affected or may affect your major customers or insured locations

Everest is not substantially dependent on any single customer, small group of customers, line of business or geographic area. For the 2022 calendar year, as we disclosed in our Form 10-K, no single customer (ceding company or insured) generated more than 3.7% of the Company’s gross written premiums. Accordingly, a severe weather event impacting any one customer would not be expected to have a material adverse effect on the Company’s financial condition or results of operations. Everest continually seeks to reduce its capacity and exposure to regions more susceptible to increased severity of climate change. Everest carefully monitors its mix of business across its operations to avoid unacceptable geographic or other risk concentrations that would materially affect demand for its products or the availability of its service.

Everest Group, Ltd. (“Everest”) is a leading global provider of reinsurance and insurance, operating for close to 50 years through subsidiaries in the U.S., Europe, Singapore, Canada, Bermuda, and other territories. Everest offers property, casualty, and specialty products through its various operating affiliates located in key markets around the world. Everest common stock (NYSE: EG) is a component of the S&P 500 index. Additional information about Everest, our people, and our products can be found on our website at www.everestglobal.com. All issuing companies may not do business in all jurisdictions.

Any weather-related impacts on the cost or availability of (re)insurance

Everest purchases reinsurance to cover specific business written or the potential accumulation or aggregation of exposures, including from weather-related causes, across all of its operations. In recent years, Everest has increased its use of reinsurance offered through capital markets facilities, and consequently has not experienced any significant impacts resulting from the cost or availability of reinsurance. Furthermore, throughout the execution of our strategic business expansion, our reinsurance purchases have remained substantially constant year over year. The future cost or availability of (re)insurance coverage in the overall insurance market will depend on a number of factors, including but not limited to, the impact of loss experience on pricing and potential climate-related laws or regulation.

Although the Company carefully monitors and reports on losses from catastrophes in its financial disclosures, it does not do so with specific focus on climate change or extreme weather events. With regard to potential future losses, Everest uses its risk modeling to assess its exposure to weather-related events but does not currently generate quantitative estimates of possible direct and indirect effects of such events, although it will continue to evaluate the need and feasibility of such quantification. In addition, Everest is not currently, and with respect to potential future losses may not be able to, determine the amount of any incremental operating expense associated with extreme weather events.

For all the reasons discussed above, the Company believes there have not been any material physical effects of climate change on its operations and results. We will continue to monitor and evaluate the potential physical effects of climate change on our business, financial condition and results of operations. While the Company believes that climate change and resulting changes in global temperatures, weather patterns, and sea levels may increase the frequency and severity of and losses resulting from future natural catastrophes and may also impact its risk modeling assumptions, it cannot predict the impact that changing climate conditions may ultimately have on its results of operations or financial condition.

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Your CSR Reports reference a five-year purchase agreement for certified carbon offsets and voluntary purchases of carbon offset credits. If material, provide disclosure about your purchase or sale of carbon credits or offsets and any material effects on your business, financial condition, and results of operations.

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Include quantitative information for each of the periods covered by your Form 10-K and for future periods in your response.

In 2021, Everest purchased certified carbon offsets for approximately twenty-one thousand dollars in connection with the LEED certification for one of its offices. As of the date of this letter, the total amount paid by Everest for the certified carbon offsets is not material to the Company’s business, financial condition, or results of operations for any historical periods and is not expected to be material in foreseeable future periods.

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To the extent any purchases or sales of carbon credits or offsets in future periods are material to the Company’s business, financial condition or results of operations, the Company will provide appropriate disclosure in accordance with applicable legal requirements regarding such transactions.

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Everest Group, Ltd. (“Everest”) is a leading global provider of reinsurance and insurance, operating for close to 50 years through subsidiaries in the U.S., Europe, Singapore, Canada, Bermuda, and other territories. Everest offers property, casualty, and specialty products through its various operating affiliates located in key markets around the world. Everest common stock (NYSE: EG) is a component of the S&P 500 index. Additional information about Everest, our people, and our products can be found on our website at www.everestglobal.com. All issuing companies may not do business in all jurisdictions.

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Your response to prior comment 2 appears to be conclusory in nature without providing sufficient detail regarding the indirect consequences of climate-related regulation or business trends as these relate to your insurance and reinsurance business, including your assessment thereof.

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Please further address the following: • Your response states, “While climate-related regulation and business trends may have some impact on the risks covered by Everest’s products and services and the prices thereof, those impacts are not material.” Tell us about the trends and impacts you considered, and how you concluded these are not material, providing support for your determination. • Your response to prior comment 3 indicates that "Climate change is an inherent component of adjustments to Everest's models" and “Everest's pricing and exposure models strive to quantify the impacts of climate change to better allow us to price the risk products we sell and how we deploy our risk capital.” Explain to us how you considered providing disclosure that specifically addresses the impacts of climate change on your business in your Form 10-K, consistent with information in your response, Proxy Statement, and CSR Reports (which highlight your exposure to "climate-related risks on both sides of the balance sheet"). • We note your response to prior comment 3 regarding insurance and reinsurance protection for renewable energy programs, together with information on pages 9-12 of your Proxy Statement regarding renewable energy products and investments. Tell us how you considered providing disclosure in your Form 10-K regarding the indirect consequences of increased demand for alternative energy in light of these products and investments.

We have concluded that a single response to both of the preceding comments will offer greater clarity than separate responses to each. Our response follows.

Regulation

Currently, and climate-related regulation of the Company centers, and for the foreseeable future we expect it will continue to center on disclosure of climate-related financial impact and expenditure metrics as well as climate-related impacts on financial estimates and assumptions in our financial statements.

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The potential impacts of regulation on the risks covered by Everest’s products and services and on business trends relates to the potential regulation of the activities of our commercial customers. Such regulation could take the form, for example, of requiring investments in reduction of greenhouse gas emissions and controls on other commercial activities (e.g., downstream pollution) that have climate impacts. Such regulation could impact the types and the extent of risk coverage that those customers may seek to purchase, which could in turn impact the price of insurance. The impacts of such regulation on the risks covered by Everest are not at present material to Everest; to date, we have not identified any such impacts that are quantifiable.

The discussion below sets forth the way Everest’s disclosures already address climate-related financial impacts and the disclosure thereof, as well as the immateriality of climate-related expenditure metrics. It also sets forth the reasons why climate change has not had and is not expected to have any material impact on the Company’s financial condition or results of operations. The discussion below also draws an important distinction in our references to climate-related impacts and disclosures as opposed to those relating to climate change.

Climate Risks and Everest’s Disclosures Thereof

We turn now to the trends and impacts we considered in preparing our disclosures of the Company’s financial condition and results of operations. Central to the quantification of climate trends by peril, their relative materiality and how Everest’s pricing and exposure models address and incorporate those trends are four key considerations:

•Everest Business Mix: Everest Group is a broadly diversified insurer and reinsurer. A majority of our overall underwriting portfolio is not exposed to climate-related risks. These alternative classes and geographies of contracts are exposed to other risk trends (in (re)insurance this is often, including in our disclosures, referred to as “actuarial trends”). In our modeling, pricing, underwriting, accumulating and reporting, the joint impacts of these trends are included in our business roll-ups included in SEC reports. The diversification across these various factors greatly minimizes the materiality of each.

Regarding weather-related risk in our current business mix, the Company’s estimated exposure to losses due to natural catastrophes (“Nat Cat,” which include severe weather events, but also other natural catastrophes) based on a recent four-year average was equal to approximately 7% of our projected annual net earned premium, or NEP (hereinafter, “Revenue”). As we have more recently reduced our exposure to Nat Cat losses, our current outlook (which we have reported consistently to investors in our earnings release commentary and other contexts) is that Nat Cat losses will amount to just under 6% of Revenue. As laid out in more detail in the next two bulleted considerations, most of this small percentage (6%) of Revenue exposure would exist independent of climate change. A simple example, as reported in our probable maximum loss (“PML”) disclosure in our Form 10-K is our catastrophe exposure to earthquakes, which constitute a part of this 6% Nat Cat load. Earthquakes are not believed to be influenced by climate change.

In 2023 to date, 5.1% of our losses, representing 3.2% of Revenue were attributable to Nat Cat. In 2022, 2021 and 2020, 13.1%, 15.4% and 6.5%, respectively, of our losses were attributable to Nat Cat, representing 9.0%, 10.9% and 4.9%, respectively, of Revenue in those periods. Treating the 3.2% in 2023 as a full-year figure, the average for the period 2020-2023 is 7.0%, which is equal to our recently estimated exposure. The development of Nat Cat losses in 2022-2023 supports our modeling projection of a decline (to just below 6%) in that long-term percentage.

As our assets and liabilities are overwhelmingly financial obligations, this financial exposure to natural catastrophes is much larger than the financial impact of climate change on our own facilities and operations, and accordingly, such impacts are also immaterial. The Staff also requested quantification of the exposure of our facilities and operations to climate change. As detailed in the response to the next comment, these exposures are separate and much smaller than our exposures to losses arising out of our insurance and reinsurance coverage of third-party risks.

•Climate-related Risk vs. Climate Change: Climate-related risk would exist in our underwriting independent of climate change. We emphasize the distinction between climate change and climate-related risk, referring to the natural weather disasters that are covered by some of our (re)insurance contracts, which existed in similar form long before the emergence of climate change. As illustrated in the example set forth below, although most of the 6% cat load is climate-related, only a small percentage can be attributed to climate change.

•Timeframe (of Climate Trends and (Re)Insurance Contracts): In setting loss models, Everest Group, cat model vendors, and the insurance industry partially rely on government-provided climate/weather data that in many cases pre-date climate change or are concurrent with the estimated 150 years of greenhouse gas emissions that scientists point to as a principal source of climate change.

Throughout this relatively long timeframe, researchers, Everest Group and the insurance industry have noted increases in the frequency and severity of certain natural perils (e.g., heatwaves, drought, intense hurricanes, extreme rainfall events) and a decrease in others (e.g., losses due to below-freezing temperatures). As an example of how this timeframe is quantified in consideration of materiality, the Hurricane Databases of the National Hurricane Center (“HURDAT”) dataset we use in modeling indicates an increase of 26% in U.S. hurricane wind risk over the entire period covered by the HURDAT dataset (1851-present). To oversimplify, an insurance policy covering hurricane wind risk written today would experience 13% more loss than an identical policy written at the midpoint of the HURDAT dataset (1937). This rate of change (i.e., 13% over 86 years) is de minimis by comparison with other risk factors (such as demographic patterns, building standards, and inflation), for which increased risk far exceeds the observed rate of change in risk due to climate-related factors.

The overwhelming majority of Everest contracts exposed to climate-related risk have an annual term. While it is necessary and impactful to capture the various cumulative impacts of climate change on these contracts, this quantification is incorporated into our loss modeling, accumulations and reporting (i.e., PMLs included in our SEC periodic reports). The short-term impact of climate change is less consequential to the annual contracts that we renew or terminate than the seasonal changes of inflation or decadal changes in the built environment and technology.

To give an example to quantify this impact of annual climate change in our overall results:

oEverest Group expects 6% of Revenue to be paid out in Nat Cat claims, o33% of these modeled Nat Cat claims in our current book are losses due to North Atlantic Hurricanes (NA HU), our largest climate-related risk (consisting of the United States, including the Southeast Wind category identified in our PMLs, the Caribbean basin and Central America).

oNA HU wind annual climate change trend: an increase of approximately 13% over the period 1937-2023 (86 years) = 0.15% oAnnual impact of climate on hurricane wind claims to Everest Group:

6% Nat Cat Loss/Everest Revenue * 33% NA HU Loss/ Cat Loss * 0.15% Climate Hurricane Wind Loss Annual Trend/NA HU Loss =

0.003% Climate NA HU Wind Loss attributable to the annual trend of increase in risk (as a percentage of Everest Revenue)

This annual trend in the hurricane wind hazard is greatly exceeded by the annual trends in how many people move into high-risk areas, how they build there and how much value they (re)insure there.

•Pricing Business Cycles and Everest Business Mix. We do observe that, notwithstanding the fact that the impacts on insured losses of many trends (e.g., climate change, demographics, inflation) is gradual, their realization and quantification by markets (clients and/or competitors) may be more discrete and discontinuous. As noted in the Company’s SEC disclosures, adjustments in the pricing cycles of insurance and reinsurance contracts more often take the form of delayed “lurches” than the gradual adjustments that reflect the evolution of risks that would be more appropriate. This disconnect between the market price of annual contracts and the risks covered by those annual contracts often necessitates changes in the business mix of the (re)insurance coverage that our Company writes for policyholders. By re-underwriting risks on an annual basis, our exposure to this business cycle risk is minimized.

The foregoing illustrates that, in our view, the consequences of climate-related business trends as they relate to our insurance and reinsurance business are not material to our financial condition or results of operations. It also explains our reasoning that, since climate change has no material impacts on our financial condition and results of operation or on the way we manage the company, disclosures thereof in our periodic reports and proxy statement are unnecessary and inappropriate for inclusion in those reports. We will consider including some of the reasoning set forth above in our next CSR.

•We note your response to prior comment 3 regarding insurance and reinsurance protection for renewable energy programs, together with information on pages 9-12 of your Proxy Statement regarding renewable energy products and investments.

Tell us how you considered providing disclosure in your Form 10-K regarding the indirect consequences of increased demand for alternative energy in light of these products and investments.

Response:

Insurance and reinsurance written in our energy programs overall represented less than 5% of Revenue in each of the years ended 2022, 2021 and 2020. Although we did not track Revenue from renewable energy in those periods, the Company believes that renewable energy risks represent a small percentage (substantially less than one-quarter) of our overall energy underwriting portfolio, with no material changes in that percentage over the reporting period. As a result, the Company determined that the indirect consequences of increased demand for alternative energy was not material information that required disclosure in the Company’s Form 10-K. We are observing some growth in this line of business and will continue to monitor and evaluate whether increased demand for alternative energy products and investments would make including such disclosures in our SEC filings necessary and appropriate, based in particular on whether disclosure of such information would be more likely to constructively educate investors or instead be more likely to confuse or mislead them.

As stated in Everest’s Proxy Statement, Everest has invested over $200 million in green bonds, which are fixed income instruments specifically designed to fund projects with environmental and/or climate or other social benefits. We also hold nearly $20 million of investments in three ESG-related exchanged-traded funds, which support the production of renewable energy in various areas of the world. These investments supporting the transition to renewable energy represented less than 1% of the Company’s investment portfolio.

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We note your response to prior comment 3 and reissue it in part. Please provide us with quantitative information for each of the periods covered by your Form 10-K regarding weather-related damages to your property and operations and the cost of reinsurance.

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In addition, tell us whether the cost of reinsurance in expected to increase in future periods, and how you considered disclosing the effects of climate-related losses, exposure, and regulation on the future cost and availability of reinsurance.

There have been no weather-related damages to the Company’s property or operations during any of the periods covered by the Company’s Form 10-K for 2022. The cost of insurance for the Company’s property and operations is not material to the Company, representing less than 0.03% of non-claim-related expense in each year of the reporting period, and the cost of reinsurance is likewise immaterial. Moreover, the cost of reinsurance is determined by the market and is influenced by many factors, which makes it impractical to attribute any particular portion of the cost to weather-related damages.

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As the cost of reinsurance is market-driven, the Company is unable to predict whether the cost will increase or decrease from period to period. We currently expect that the effects of climate-related losses, exposures and regulation on the future cost and availability of reinsurance for our property and operations will be immaterial. To the extent such effects become material, the Company would disclose such effects in accordance with its disclosure obligation under U.S. federal securities laws.

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Basis of Presentation Application of Recently Issued Accounting Standard Changes, page 6 1. You state that you are the primary beneficiary of Mt. Logan Re, but not of the underlying separate segregated accounts and therefore have deconsolidated those segregated accounts. Please tell us if the segregated accounts are required to be included in the financial statements of Mt.

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Logan Re in which you are the primary beneficiary, and if so, why deconsolidation of these accounts is in accordance with GAAP. Provide us a detailed analysis of your accounting for the deconsolidation of the separate segregated accounts under ASU 2015-02. 13. Segment Reporting, page 27 2. Please tell us the basis for no longer reporting Mt. Logan Re as a separate segment. Refer to ASC 280-10-50-10. In this regard, please tell us if your organizational structure, as noted on your website, has changed.

Mt. Logan Re is a Class 3 insurer registered in Bermuda under The Segregated Accounts Act 2000. Under the provisions of The Segregated Accounts Act 2000, each segregated account (or silo) must economically stand on its own. Each silo is governed by its shareholders, must fully collateralize its obligations and no silo has recourse to the general account (host) or to the other silos.

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The silos offer capital market investors the opportunity to gain exposure to the risk-reward profile of diversifying, non-correlated reinsurance risks via privately offered insurance linked securities in the form of preference shares. Conversely, Mt. Logan Re as the host insurer is not permitted to write business in its own account. In addition, Mt Logan Re is required to exclude its segregated accounts business (silos) from its statutory income statement in its annual filings with the Bermuda Regulatory Authority. On the balance sheet, all assets related to the segregated account business are reflected on a single asset line and correspondingly, all liabilities from the segregated account business are recorded on a single liability line.

GAAP Consolidation Evaluation and Analysis

The Company performed a detailed evaluation and analysis of ASU 2015-02, pursuant to ASC 810.

The Company's analysis began with a series of scope questions for determining which consolidation model should apply under U.S. GAAP. Specifically: (1) Does Mt. Logan Re as the host and each segregated cell (silo) meet the definition of a legal entity for purposes of applying the consolidation guidance in ASC 810, (2) Is the host entity a Variable Interest Entity ("VIE"), (3) determine the primary beneficiary of the host entity and (4) determine the primary beneficiaries of each silo.

The Codification defines "legal entity" as almost any legal structure that is used to own assets, issue debt, or otherwise conduct activities. Mt. Logan Re, the general account, (the host) is a legal entity wholly owned by the Company. Each of the segregated cells were deemed to be a silo within Mt. Logan Re and are also considered to be a separate VIE due to:

All of the assets, liabilities, and equity related to segregated cells are separate from the other cells and the remainder of the legal entity, the general (host) account.

None of the liabilities or claims associated with the segregated cells are payable from the other cells or the remainder of the assets of the legal entity, the general (host) account.

Per the consolidation requirements in ASC 810-10-15-1, there are only four general exceptions to the requirements for consolidating a legal entity. Broadly speaking, the exceptions apply to (1) employee benefit plans, (2) investment companies, (3) governmental entities, and (4) money market funds.

None of these scope exceptions apply to Mt. Logan Re.

There are four scope exceptions to application of the VIE model: (1) Not-for-profit entities, (2) Separate accounts of life insurance entities, (3) Exhaustive efforts, and (4) Business entities.

Does the reporting entity have a variable interest in the legal entity?

Yes, pursuant to ASC 810-10: 55-17 the identification of variable interests requires an economic analysis of the rights and obligations of a legal entity's assets, liabilities, equity, and other contracts. Variable interests are contractual, ownership, or other pecuniary interests in a legal entity that change with changes in the fair value of the legal entity's net assets exclusive of variable interests. The VIE subsections use the terms expected losses and expected residual returns to describe the expected variability in the fair value of a legal entity's net assets exclusive of variable interests.

The Company does have a majority interest in the legal entity Mt. Logan Re (the Host) and does have an overall minor participation in the total segregated cell investments:

The Company owns 100% of the common equity in the core (host) entity and therefore the core entity is an Everest Re Group, Ltd. VIE. Management concluded there was insufficient equity at risk and as such the host entity qualifies as a VIE. This represents a change in accounting policy which was adopted concurrent with the adoption of ASU 2015-02. This is consistent with the SEC position shared with the Securities Industry and Financial Markets Association with respect to umbrella entities for international series funds.

Having determined that the host entity is a VIE, management then considered whether the Company has a variable interest in the silos and effectively treated them as separate legal entities for consideration. The term host refers to the remaining legal entity after removal of all the identified silos. When silos exist and the host is a VIE, the units of account for potential consolidation are each respective silo and the host itself.

ASC 810-10-25-38 Subsequent to ASU 2015-02) states that: A reporting entity shall consolidate a VIE when that reporting entity has a variable interest (or combination of variable interests) that provides the reporting entity with a controlling interest on the basis of the provisions in paragraphs 810-10-25-38A through 25-38J. The reporting entity that consolidates a VIE is called the primary beneficiary of that VIE. Pursuant to ASC 810-10-25-38A, a reporting entity is deemed to have a controlling financial interest in a VIE if it has both of the following characteristics:

The power to direct activities of a VIE that most significantly impact the VIE's economic performance, and

The obligation to absorb losses of the VIE that could potentially be significant to the VIE or the right to receive benefits from the VIE that could potentially be significant to the VIE. The quantitative approach described in the definition of the terms expected losses, expected residual returns and expected variability is not required and shall not be the sole determinant as to whether a reporting entity has these obligations or rights.

The Company has both characteristics of a controlling financial interest in Mt. Logan Re (host) but very limited power and economic exposure in the silos.

In the host entity, Everest Re Group, Ltd. controls the election of Board of Directors, has all the decision making powers and has sole interest in all operating results.

In the segregated cells or silos, the power and economic benefits rest with the preferred stockholders of each silo. At December 31, 2015, there were 10 active capitalized silos with total capital of $812.5 million. Of this amount, $50.0 million, or approximately 6%, spread across 4 of the 10 segregated silos, represented capital from the Company. The balance of the capital represents investments by non-related third party investors. The $50.0 million represents primarily start-up or seed money for new funds to attract additional investors and has the same power and economic benefits as the third party investors. For 3 of the 4 silos invested in by the Company, the ownership percentage was less than a majority, 6.2%, 7.3% and 16.9%. The Company's investment in one cell represented 61.5% of the total capital in the cell; however, the total capital in that cell was less than 5% of the total capital in all cells. The Company's intent is not to be a majority shareholder in any of the cells for any extended period of time. As a result, of the relative immateriality of the Company's investment in these cells and the Company's intent not to continue to be a majority shareholder of any cell, management determined it was not necessary to continue to consolidate the cells.

Conclusion

The Host:

Based on the facts and circumstances analyzed, Mt. Logan, the host entity is a VIE and should be and is consolidated as the Company is the primary beneficiary of this entity.

The Segregated cells (silos):

Considering the above criteria and the following summarized facts and circumstances, the Company determined that it was appropriate to analyze each silo for consolidation. The Company determined that consolidation was not necessary as it was not the primary beneficiary for the cells in which it has an ownership interest less than 10% for consolidation and an analysis of whether the Company was the primary beneficiary for the remaining two cells was not deemed necessary given the immaterial nature of such cells. As such, the Company deconsolidated all ten of the segregated cells.

These facts and circumstances include:

The host parent entity is a VIE as it lacks sufficient equity at risk

Each segregated cell has its own underwriting/investment objectives and policies

Each segregated cell has its own investors separate from other cells

Each segregated cell is considered a separate silo for investor protections in virtually all circumstances

Each segregated cell is operating on a standalone basis for the benefit of the investors within that cell.

The Company has a relatively small investment in the cells to provide seed money or show "skin in the game" for third party investors.

No investment in any segregated cell is material/significant in a monetary sense nor is it in a combined sense. The value/percentage of the Company's investment in each segregated cell decreases as external investors buy into the cell and/or as the Company withdraws the seeding money.

The Company has concluded that it is the primary beneficiary of Mt. Logan Re Core, but not of the underlying separate segregated cells and therefore has deconsolidated these segregated cells. This change has no impact to the net income or retained earnings attributable to the consolidated financial statements for Everest Re Group, Ltd.

The Company's investment in the cells is reflected as part of other assets and the income from the cells is reflected in other income. The amounts are not material to the overall operations of the Company. The income generated from the Core or Host company is also reflected in other income.

The Company applied a retrospective approach and deconsolidated all prior periods because this makes the financial statements comparable for all periods.

13. Segment Reporting, page 27

2. Please tell us the basis for no longer reporting Mt. Logan Re as a separate segment. Refer to ASC 280-10-50-10. In this regard, please tell us if your organizational structure, as noted on your website, has changed.

Response:

Virtually all of the activity previously reported in the Mt. Logan Re segment related to the underwriting results of the segmented silos of Mt. Logan Re and by deconsolidating the silos, the remaining activity in the core entity does not meet the materiality criteria for separate reporting under ASC 280-10-50-10. The total of the Company's underwriting income from their seed money in the silos combined with the commission income for the host consolidated entity is less than 2.5% of the total pretax consolidated net income for the Company for the year ended December 31, 2015.

Our organizational structure, as reflected on our website has not changed. Mt. Logan Re is still an owned legal entity, even though the segregated silos under Mt. Logan Re have been deconsolidated.

Please let me know if you require any additional information.

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Fair Value, page F-20 1. Your discussion on page F-21 of how valuations for your level 2 fixed maturity securities are derived appears to be vague. Please provide us, for each “class” (refer to comment two) of Level 2 fixed maturity securities, the valuation technique(s) and inputs used in your fair value measurement. Refer to ASC 820-10-50-2bbb. 2.

Rest of the question

Refer to your disclosure of fixed maturity securities herein and in Note 2. It is unclear to us why further disaggregation of your fixed maturity securities is not warranted. Please provide us analyses under ASC 320-10-50-1B and ASC 820-10-50-2B supporting your presentation of fixed maturity securities by “major security types” and “classes.” In this regard, please tell us why you did not further disaggregate corporate securities, agency residential, foreign government securities and foreign corporate securities.

The Company will enhance and expand its fair value disclosures in future filings by including the following lead-in before the fair value tables:

“Generally Accepted Accounting Principles (“GAAP”) guidance regarding fair value measurements address how companies should measure fair value when they are required to use fair value measures for recognition or disclosure purposes under GAAP and provides a common definition of fair value to be used throughout GAAP.

Rest of the answer

It defines fair value as the price that would be received to sell an asset or paid to transfer a liability in an orderly fashion between market participants at the measurement date. In addition, it establishes a three-level valuation hierarchy for the disclosure of fair value measurements. The valuation hierarchy is based on the transparency of inputs to the valuation of an asset or liability. The level in the hierarchy within which a given fair value measurement falls is determined based on the lowest level input that is significant to the measurement, with Level 1 being the highest priority and Level 3 being the lowest priority.

The levels in the hierarchy are defined as follows:

Level 1: Inputs to the valuation methodology are observable inputs that reflect unadjusted quoted prices for identical assets or liabilities in an active market;

Level 2: Inputs to the valuation methodology include quoted prices for similar assets and liabilities in active markets, and inputs that are observable for the asset or liability, either directly or indirectly, for substantially the full term of the financial instrument;

Level 3: Inputs to the valuation methodology are unobservable and significant to the fair value measurement.

The Company’s fixed maturity and equity securities are primarily managed by third party investment asset managers. The investment asset managers obtain prices from nationally recognized independent pricing services. These services seek to utilize market data and observations in their evaluation process. They use pricing applications that vary by asset class and incorporate available market information and when fixed maturity securities do not trade on a daily basis the services will apply available information through processes such as benchmark curves, benchmarking of like securities, sector groupings and matrix pricing. In addition, they use model processes, such as the Option Adjusted Spread model to develop prepayment and interest rate scenarios for securities that have prepayment features.

In limited instances where prices are not provided by pricing services or in rare instances when a manager may not agree with the pricing service, price quotes on a non-binding basis are obtained from investment brokers. The investment asset managers do not make any changes to prices received from either the pricing services or the investment brokers. In addition, the investment asset managers have procedures in place to review the reasonableness of the prices from the service providers and may request verification of the prices. In addition, the Company continually performs analytical reviews of price changes and tests the prices on a random basis to an independent pricing source. No material variances were noted during these price validation procedures. In limited situations, where financial markets are inactive or illiquid, the Company may use its own assumptions about future cash flows and risk-adjusted discount rates to determine fair value. The Company made no such adjustments at December 31, 20XX and 20XX.

The Company internally manages a small public equity portfolio which had a fair value at December 31, 20XX and December 31, 20XX of $XXX,XXX thousand and $XXX,XXX thousand, respectively, and all prices were obtained from publically published sources.

Equity securities denominated in U.S. currency with quoted prices in active markets for identical assets are categorized as level 1 since the quoted prices are directly observable. Equity securities traded on foreign exchanges are categorized as level 2 due to the added input of a foreign exchange conversion rate to determine fair or market value. The Company uses foreign currency exchange rates published by nationally recognized sources.

All categories of fixed maturity securities listed in the tables below are generally categorized as level 2, since a particular security may not have traded but the pricing services are able to use valuation models with observable market inputs such as interest rate yield curves and prices for similar fixed maturity securities in terms of issuer, maturity and seniority. For foreign government securities and foreign corporate securities, the fair values provided by the third party pricing services in local currencies, and where applicable, are converted to U.S. dollars using currency exchange rates from nationally recognized sources.

The fixed maturities with fair values categorized as level 3 result when prices are not available from the nationally recognized pricing services. The asset managers will then obtain non-binding price quotes for the securities from brokers. The single broker quotes are provided by market makers or broker-dealers who are recognized as market participants in the markets in which they are providing the quotes. The prices received from brokers are reviewed for reasonableness by the third party asset managers and the Company. If the broker quotes are for foreign denominated securities, the quotes are converted to U.S. dollars using currency exchange rates from nationally recognized sources. Historically, most of the level 3 fixed maturities have resulted from new issuances and the third party prices services have not yet included the issuance in their data base. Generally, in subsequent measurement periods, the issuances will be included in the data base and the fair value will transfer to level 2.

The composition and valuation inputs for the presented fixed maturities categories are as follows:

U.S. Treasury securities and obligations of U.S. government agencies and corporations are primarily comprised of U.S. Treasury bonds and the fair value is based on observable market inputs such as quoted prices, reported trades, quoted prices for similar issuances or benchmark yields;

Obligations of U.S. states and political subdivisions are comprised of state and municipal bond issuances and the fair values are based on observable market inputs such as quoted market prices, quoted prices for similar securities, benchmark yields and credit spreads;

Corporate securities are primarily comprised of U.S. corporate and public utility bond issuances and the fair values are based on observable market inputs such as quoted market prices, quoted prices for similar securities, benchmark yields and credit spreads;

Asset-backed and mortgage-backed securities fair values are based on observable inputs such as quoted prices, reported trades, quoted prices for similar issuances or benchmark yields and cash flow models using observable inputs such as prepayment speeds, collateral performance and default spreads;

Foreign government securities are comprised of global non-U.S. sovereign bond issuances and the fair values are based on observable market inputs such as quoted market prices, quoted prices for similar securities and models with observable inputs such as benchmark yields and credit spreads and then, where applicable, converted to U.S. dollars using an exchange rate from a nationally recognized source;

Foreign corporate securities are comprised of global non-U.S. corporate bond issuances and the fair values are based on observable market inputs such as quoted market prices, quoted prices for similar securities and models with observable inputs such as benchmark yields and credit spreads and then, where applicable, converted to U.S. dollars using an exchange rate from a nationally recognized source.

The Company’s liability for equity index put options is categorized as level 3 since there is no active market for these seven long dated equity put options. The fair values for these options are calculated by the Company using an industry accepted pricing model, Black-Scholes. The model inputs and assumptions are: risk free interest rates, equity market indexes values, volatilities and dividend yields and duration. The model results are then adjusted for the Company’s credit default swap rate. All of these inputs and assumptions are updated quarterly. One of the option contacts is in British Pound Sterling so the fair value for this contract is converted to U.S. dollars using an exchange rate from a nationally recognized source.

The Company sold these seven equity index put option contracts, based on two indices, in 2001 and 2005, which remain outstanding. The Company sold these equity index put options as insurance products with the intent of achieving a profit. These equity index put option contracts meet the definition of a derivative under FASB guidance and the Company’s position in these equity index put option contracts is unhedged. Accordingly, these equity index put option contracts are carried at fair value in the consolidated balance sheets with changes in fair value recorded in the consolidated statements of operations and comprehensive income (loss).

The Company sold six equity index put option contracts, based on the Standard & Poor’s 500 (“S&P 500”) index, for total consideration, net of commissions, of $22,530 thousand. At December 31, 20XX, fair value for these equity index put option contracts was $XX,XXX thousand. Based on historical index volatilities and trends and the December 31, 20XX S&P 500 index value, the Company estimates the probability that each equity index put option contract of the S&P 500 index falling below the strike price on the exercise date to be less than XX%. The theoretical maximum payouts under these six equity index put option contracts would occur if on each of the exercise dates the S&P 500 index value were zero. At December 31, 20XX, the present value of these theoretical maximum payouts using a X% discount factor was $XXX,XXX thousand. Conversely, if the contracts had all expired on December 31, 20XX, with the S&P index at $X,XXX.XX, there would have been no settlement amount.

The Company sold one equity index put option contract based on the FTSE 100 index for total consideration, net of commissions, of $6,706 thousand. At December 31, 20XX, the fair value for this equity index put option contract was $X,XXX thousand. Based on historical index volatilities and trends and the December 31, 20XX FTSE 100 index value, the Company estimates the probability that the equity index put option contract of the FTSE 100 index will fall below the strike price on the exercise date to be less than XX%. The theoretical maximum payout under the equity index put option contract would occur if on the exercise date the FTSE 100 index value was zero. At December 31, 20XX, the present value of the theoretical maximum payout using a X% discount factor and current exchange rate was $XX,XXX thousand. Conversely, if the contract had expired on December 31, 20XX, with the FTSE index at ₤X,XXX.XX, there would have been no settlement amount.

The following table presents the fair value measurement levels for all assets and liabilities, which the Company has recorded at fair value (fair and market value) as of the periods indicated:”

2. Refer to your disclosure of fixed maturity securities herein and in Note 2. It is unclear to us why further disaggregation of your fixed maturity securities is not warranted. Please provide us analyses under ASC 320-10-50-1B and ASC 820-10-50-2B supporting your presentation of fixed maturity securities by “major security types” and “classes”. In this regard, please tell us why you did not further disaggregate corporate securities, agency residential, foreign government securities and foreign corporate securities.

Response:

The Company developed its disclosures in Note 2 to comply with the reporting requirements set forth in ASC 944-320-50 and ASC 942-320-50; Investments—Debt and Equity Securities. The investment categories in Note 2, page F-13 are consistent with the security types detailed in ASC 942-320-50-2. In addition, the maturity tables reflected on page F-14 are consistent with the requirements referenced in ASC 942-320-50-3. The Company also considered whether any further break down of the investment categories; such as by geographical concentration, credit quality or by additional business sectors would provide further significant meaningful information concerning the investment portfolio. The Company determined that there are no significant sub-categories of the presented investments categories that would provide additional meaningful information.

The guidance under sections ASC 320-10-50-1B and ASC 820-10-50-2B to determine the appropriate level of breakout of asset and liabilities focuses on the nature, characteristics and risks of the asset or liability, as well as, the level of the fair value hierarchy within which the fair value measurement is categorized. Particular emphasis is placed on assets or liabilities with a level 3 fair value hierarchy because those measurements have a high degree of uncertainty and subjectivity.

Based on this criteria in conjunction with the composition of the investment portfolio, the Company does not believe a further breakout of the investments into additional classes is necessary. At December 31, 2014, only 0.12% of the entire fixed maturities portfolio was reflected under the level 3 hierarchy, with all other fixed maturities reflected under level 2. Furthermore, as reflected in Note 2. Investments, the total gross unrealized losses in the fixed maturity portfolio was only 1.2% and the largest gross unrealized loss to fair value by investment category was only 1.8% for the foreign government securities. Within each presented category of investments, the general characteristics and riskiness of the investments are not significantly different. Even though the corporate securities, agency residential, foreign government securities and foreign corporate securities categories are larger than the other categories, any further breakout of the securities would not provide an investor with any significant additional valuable information.

If disparities as to characteristics and risk arise within the presented categories in the future, the Company would provide a further breakout of the securities.

Please let me know if you require any additional information.

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We note that in Part III you incorporate by reference certain information from your definitive proxy statement for your 2013 annual meeting of shareholders. Please note that we will be unable to complete our review of your Form 10-K until such time as you have filed and we have reviewed the information required in Part III, at which time, we may have additional comments.

The Company acknowledges there may be additional comments following the staff’s review of its proxy statement. Read in the reply ↗

Please provide us proposed disclosure to be included in future periodic reports that explains the relationship between pre-tax income (loss) for your US and non-US operations and the corresponding underwriting gains (losses) for your operating segments for each period presented.

Rest of the question

For example, your US Reinsurance and Insurance segments produced combined underwriting losses of $97.8 million in 2012 and $200.4 million in 2011, while you reported US pre-tax income of $432.3 million and US pre-tax losses of $395.2 million in these years, respectively. Include an explanation of how the reconciling items disclosed on page F-49 were allocated in your determination of pre-tax income (loss) for your US and non-US operations and the factors underlying changes in this allocation process for each period presented. Also, provide us proposed disclosure that explains the trends and expected future trends in pre-tax income (loss) for your US and non-US operations. Notes to Consolidated Financial Statements 15. Dividend Restrictions and Statutory Financial Information, page F-41

In Footnote 11, INCOME TAXES on page F-29, the Company discloses that …”The provision for income taxes in the consolidated statement of operations and comprehensive income (loss) has been determined in accordance with the individual income of each entity and the respective applicable tax laws”… The pre-tax income (loss) split between US and non-US is an accumulation of actual results based on each entity’s country of domicile. Conversely, the operating segments are not determined or managed on a strict US versus non-US basis.

Rest of the answer

This is addressed in the segment definitions which disclose a mixture of US and non-US business in the International and Insurance segments. In addition, the Company discloses that business is generally reported in the segment where it is first produced, before the impact of any inter-affiliate reinsurance.

Under Part II, Item 7, Industry Conditions, the Company describes the overall global insurance and reinsurance market conditions. As explained above, some of the international business written by the company results in pre-tax US income. As a result, favorable global market conditions should result in both increased US pre-tax income, as well as, non-US pretax income. Generally, there are not distinctive market trends that would enable the Company to anticipate a greater or lesser movement in its US versus non-US pre-tax income. The fluctuations in the US versus non-US pretax income generally result from how each of its subsidiaries is impacted from catastrophic events and fluctuations in realized investment gains (losses).

To enhance its US and non-US income disclosure, the Company will expand the second paragraph of Footnote 11, INCOME TAXES in future filings as follows: Pre-tax income generated by Group’s non-Bermuda subsidiaries and the UK branch of Bermuda is subject to applicable federal, foreign, state and local taxes on corporations. Company subsidiaries domiciled in the US, as well as, the Canadian and Singapore branches of Everest Re generate US pre-tax income (loss). Foreign domiciled subsidiaries, including the UK branch of Bermuda Re, generate non-US pre-tax income (loss). Fluctuations in US and non-US pre-tax income (loss) primarily result from the impact of catastrophe losses and realized investment gains (losses) on each subsidiary and branch.

Notes to Consolidated Financial Statements

15. Dividend Restrictions and Statutory Financial Information, page F-41

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Please provide us the following information as proposed disclosure to be included in future periodic filings:  Disclose the amount of statutory capital and surplus necessary to satisfy regulatory requirements if significant in relation to the entity’s statutory capital and surplus, as required under ASC 944-505-50-1b. If not significant, clarify in the disclosure.

Rest of the question

 Disclose the amounts of restricted net assets of subsidiaries as of December 31, 2012 or tell us how your current disclosure meets the objective of Rule 4-08(e) (3) (ii) of Regulation S-X.

The minimum required regulatory statutory and surplus is not meaningful given the size of the Company’s principal operating insurance entities. The Company believes that the more meaningful information is the amount of capital that the operating entities may dividend to its holding companies without prior regulatory approval. The Company also believes that its current disclosure meets the requirements of Rule 4-08(e) (3) (ii) of Regulation S-X.

Rest of the answer

Footnote 5, Credit Facilities and Footnote 8, Junior Subordinated Debt Securities Payable disclose the amount of parent company capital and the amount of statutory surplus of Everest Reinsurance Company, “Everest Re”, that must be maintained to comply with debt covenants. The Company also views statutory capital and surplus that cannot be returned to the parent company without prior regulatory approval as being subject to regulatory restriction.

The Company will expand Footnote 15, Dividend Restrictions and Statutory Information in future filings as follows:

Statutory Financial Information.

Everest Re prepares its statutory financial statements in accordance with accounting practices prescribed or permitted by the National Association of Insurance Commissioners (“NAIC”) and the Delaware Insurance Department. Prescribed statutory accounting practices are set forth in the NAIC Accounting Practices and Procedures Manual. The capital and statutory surplus of Everest Re was $2,612,995 thousand and $2,322,115 thousand at December 31, 2012 and 2011, respectively. The statutory net income of Everest Re was $359,816 thousand for the year ended December 31, 2012, the statutory net loss of Everest Re was $326,400 thousand for the year ended December 31, 2011 and the statutory net income of Everest Re was $218,452 thousand for the year ended December 31, 2010.

The $2,612,995 thousand of capital and statutory surplus at December 31, 2012 exceeded minimum regulatory requirements. The balance of the capital and statutory surplus, after permitted dividends of $359,026 thousand, is subject to regulatory restrictions.

Bermuda Re prepares its statutory financial statements in conformity with the accounting principles set forth in Bermuda in The Insurance Act 1978, amendments thereto and related regulations. The statutory capital and surplus of Bermuda Re was $2,904,406 thousand and $2,736,599 thousand at December 31, 2012 and 2011, respectively. The statutory net income of Bermuda Re was $475,353 thousand, $97,359 thousand and $391,862 thousand for the years ended December 31, 2012, 2011 and 2010, respectively.

The $2,904,406 thousand of statutory capital and surplus at December 31, 2012 exceeded minimum regulatory requirements. The balance of the statutory capital and surplus, after permitted dividends of $726,101 thousand, is subject to regulatory restrictions.”

Please let me know if you require any additional information.

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Refer to your response to prior comment two. Please provide us the break out of each reconciling item for each year disclosed in the table on page F-49 between US and non- US pre-tax income (loss). Also explain for us the basis for determining US versus non- US pre-tax income (loss) for each of the reconciling items for each year presented.

Rest of the question

In addition, tell us the intent of your disclosure that “net income deriving from and assets residing in individual foreign countries in which the Company writes business are not identifiable in the Company’s financial records” and what effect it has on your assertions regarding amounts disclosed in the financial statements and related notes.

The following table provides the split between US and non-US income/(expense) for underwriting gain (loss) and the reconciling items comprising pre-tax income (loss):

Year Ended December 31, 2012

(Dollars in thousands)

U.S.

Non- U.S.

Total

Underwriting gain (loss)

$

42,774

216,228

259,003

Net investment income

287,382

312,820

600,202

Net realized capital gains (losses)

143,326

21,073

164,400

Net derivative gain (loss)

-

(9,738

)

Corporate expenses

(8,764

(15,211

(23,976

Interest, fee and bond issue cost amortization expense

(50,746

(2,936

(53,683

Other income

Rest of the answer

(expense)

18,360

(15,042

3,318

Income (loss) before taxes

432,332

507,194

939,526

Year Ended December 31, 2011

(574,141

(183,641

(757,781

292,980

327,062

620,041

(28,565

35,488

6,923

(11,261

(6,073

(10,388

(16,461

(50,763

(1,556

(52,319

(28,644

5,556

(23,089

(395,206

161,260

(233,947

Year Ended December 31, 2010

(138,501

29,303

(109,200

326,321

327,142

653,463

2,774

99,137

101,911

(1,119

(5,867

(9,047

(14,914

(54,553

(1,277

(55,830

10,968

5,958

16,927

141,142

450,097

591,238

The basis of the split between US and non-US income (loss) for each item is based upon the country of incorporation for the entities within the consolidated group. The operating results for all companies incorporated in the US comprise the US pre-tax results and all other entities comprise the non-US pre-tax results.

In future filings, the Company will expand the Income Taxes footnote (footnote 11 on page F-29 for the December 31, 2012 filing) to include the above components of US versus non-US pre-tax income (loss):

The weighted average expected tax provision has been calculated using the pre-tax income (loss) in each jurisdiction multiplied by that jurisdiction’s applicable statutory tax rate. Reconciliation of the difference between the provision for income taxes and the expected tax provision at the weighted average tax rate for the periods indicated is provided below:

Years Ended December 31,

2012

2011

2010

Pre-tax income (loss)

Expected tax provision at the applicable statutory rate(s)

151,316

11,013

(138,322

12,216

49,436

33,716

Increase (decrease) in taxes resulting from:

Tax exempt income

(20,623

(33,672

(56,457

Dividend received deduction

(8,351

(6,893

(2,784

Proration

3,138

5,080

8,510

Tax audit settlement

(2,508

(710

(36,511

Uncertain tax positions

(31,912

8,139

(5,237

Other

5,377

3,123

(1,471

2,172

(11,529

1,340

Total income tax provision

96,437

14,136

(167,849

14,388

(54,572

35,056

The disclosure “net income deriving from and assets residing in individual foreign countries in which the Company writes business are not identifiable in the Company’s financial records” addresses segment reporting disclosure requirement 280-10-50-41, Information About Geographic Areas. This disclosure indicates that the Company does not maintain financial statements by individual countries; however, it is able to provide gross written premiums for the largest country outside of the US.

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You assert that “operating segments are not determined or managed on a strict US or non-US basis.” However, your disclosure on page F-47 appears to indicate that business written by your US reinsurance and Insurance operations is predominantly in the US and that written by your International and Bermuda operations is predominantly in foreign countries.

Rest of the question

For example, your disclosure states that your US Reinsurance operation writes business “primarily within the US” and your International operation writes “non-US property-and casualty reinsurance.” Please provide us proposed disclosure to be included in future filings that explains how each of your operating segments is managed with regard to business written in the US and non-US markets. Notes to Consolidated Financial Statements 15. Dividend Restrictions and Statutory Financial Information, page F-41

The segments are managed based upon type of business: reinsurance versus insurance. Reinsurance is further segregated geographically by US, International, which encompasses Canada, Asia and South America and Bermuda, which includes Bermuda, Ireland, UK and Europe. Historically, the reference to US versus non-US in the segment definitions was geographical in nature as opposed to indicating whether the business was subject to US tax.

Rest of the answer

In future filings, the Company will eliminate the reference to non-US business to eliminate any confusion as to the tax status of the business as follows:

The U.S. Reinsurance operation writes property and casualty reinsurance and specialty lines of business, including Marine, Aviation, Surety and A&H business, on both a treaty and facultative basis, through reinsurance brokers, as well as directly with ceding companies primarily within the U.S. The International operation writes foreign property and casualty reinsurance through Everest Re’s branches in Canada and Singapore and through offices in Brazil, Miami and New Jersey. The Bermuda operation provides reinsurance and insurance to worldwide property and casualty markets through brokers and directly with ceding companies from its Bermuda office and reinsurance to the United Kingdom and European markets through its UK branch and Ireland Re. The Insurance operation writes property and casualty insurance, including medical stop loss insurance, directly and through general agents, brokers and surplus lines brokers within the U.S. and Canada.

Notes to Consolidated Financial Statements

15. Dividend Restrictions and Statutory Financial Information, page F-41

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Please refer to prior comment three. Please quantify for us the net assets for Everest Re and Bermuda Re on a GAAP-basis that are subject to regulatory restrictions. Provide us proposed disclosure to be included in future filings, as applicable.

The regulatory capital requirements for our licensed insurance subsidiaries are based upon statutory capital as opposed to GAAP basis equity or net assets. These requirements limit the amount of dividends that the subsidiaries may declare to its parent without prior regulatory and stipulate the amount of statutory capital that is required to be maintained at each subsidiary. These statutory based requirements are standard industry practice and the Company believes these disclosures meet the requirements of Rule 4-08(e) (3) (ii). Please see response to comment 4.

Rest of the answer

below for proposed future disclosure regarding required regulatory capital.

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Please refer to prior comment three. As previously requested, please provide us proposed disclosure to be included in future filings of the amount of statutory capital and surplus necessary to satisfy regulatory requirements if significant in relation to the entity’s statutory capital and surplus, as required under ASC 944-505-50-1b. If not significant, clarify in proposed disclosure to be included in future filings.

The Company’s licensed insurance entities are subject to annual capital adequacy tests by the applicable regulators. These tests use risk based models using individual entity exposures to determine a minimum capital and surplus level. This minimum level is then compared to the actual capital and surplus level to determine if the entity has sufficient capital. As examples, the Company’s two major operating subsidiaries, Everest Re and Bermuda Re are subject to capital adequacy testing by their regulators.

Rest of the answer

Everest Re is subject to the Risk-Based Capital model (RBC) developed by the National Association of insurance Commissioners and at December 31, 2012, its determined authorized control level risk-based capital was

$673.1 million compared to its total adjusted capital of $2.6 billion. As long as the total adjusted capital is 200% or more of the authorized control level capital, no action is required by the Company.

Bermuda Re is subject to the Bermuda Solvency Capital Requirement (BSCR) administered by the Bermuda Monetary Authority (BMA). No regulatory action is taken if an insurer’s capital and surplus is equal to or in excess of their enhanced capital requirement determined by the BSCR model. In addition, the BMA has established a target capital level for each insurer, which is 120% of the enhanced capital requirement. Using December 31, 2012 data, Bermuda Re’s target capital level was $2.0 billion compared to actual statutory capital and surplus of $2.9 billion.

In future filings, the Company will add the following paragraph to its Dividend Restrictions and Statutory Financial Information footnote:

In addition to dividend restrictions, each of the Company’s operating insurance and reinsurance entities are subject to statutory capital and surplus requirements by their applicable regulators. These requirements are based upon the results from risk-based models using inputs for individual entities. These models generally develop a minimum capital and surplus level, along with a higher targeted capital and surplus level. In all instances, the statutory capital and surplus levels for the individual entities exceed the regulatory targeted levels.

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You have disclosed that the increase in Losses and LAE from 2010 to 2011 was a result of a $713.9 million increase in catastrophe losses in 2011 compared to 2010 primarily due to losses from the Japan and New Zealand earthquakes, Thailand floods, U.S. storms, Australia floods and Hurricane Irene.

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You have also disclosed that the increase in Losses and LAE from 2009 to 2010 was a result of a $571.6 million increase in catastrophe losses primarily due to losses on the Chilean earthquake, New Zealand earthquake, Australian hailstorms and floods, and the Canadian hailstorm. Please provide us proposed disclosure to be included in future periodic reports to quantify each significant factor that resulted in the significant increase. For example, disclose the amount recorded for each significant catastrophe event that occurred in each year.

Beginning with the quarter ending June 30, 2012, the Company will expand its discussion of variances in Incurred Losses and Loss Adjustment Expenses by quantifying each significant factor resulting in significant variances in year-over-year comparisons. For example, the Company will identify the losses associated with each catastrophic event cited within the variance discussion. The Company will provide this additional quantification of significant factors both in ITEM 2.

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MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF

Everest Re Group, Ltd

OPERATION under CLAIMS AND EXPENSES, as directed above, and in ITEM 2. MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATION under SEGMENT RESULTS, where applicable.

As an example, if such language had been included in ITEM 2. MANAGEMENT’S DISCUSSION AND ANALYSIS OF FINANCIAL CONDITION AND RESULTS OF OPERATION under CLAIMS AND EXPENSES on page 48 of the December 31, 2011 Form 10-K, the variance discussion would have read as follows (revisions shown in italics):

“Incurred losses and LAE increased by $780.5 million, or 26.5%, for the year ended December 31, 2011 compared to the same period in 2010. Of the $780.5 million increase, current year catastrophe losses increased $713.9 million, or 16.8 points, period over period, to $1,300.4 million. The 2011 current year catastrophe losses are primarily comprised of losses from the Japan earthquake ($531.7 million), New Zealand 2011 earthquake ($305.8 million), Thailand floods ($225.0 million), U.S. storms ($60.6 million), Australia 2011 floods ($56.1 million) and Hurricane Irene ($38.0 million) as well as $50.0 million of IBNR reserves for these 2011 catastrophe events collectively, which were not allocated to a specific event. In addition, the overall attritional losses increased $50.3 million due, in part, to higher earned premium in the current year, which generated higher attritional losses for the current year, as well as the impact of favorable development in 2010 without comparable favorable development in 2011.

Incurred losses and LAE increased by $571.6 million, or 24.1%, for the year ended December 31, 2010 compared to the same period in 2009. Of the $571.6 million increase, current year catastrophe losses increased $522.7 million (13.3 points), period over period, to $586.5 million. The 2010 current year catastrophe losses were comprised of losses on the Chilean earthquake ($416.2 million), New Zealand 2010 earthquake ($90.0 million), Australian 2010 hailstorms and floods ($65.3 million), and the Canadian hailstorm ($15.0 million). The current year attritional losses also increased $208.7 million (4.8 points) reflecting higher expected loss ratios on current year business due to prevailing market conditions. Partially offsetting these higher current year losses was a decrease of $159.6 million, or 4.1 points, in prior year loss development as the 2010 reserve studies indicated net favorable reserve development of $30.8 million compared with net unfavorable reserve development in 2009 of $128.8 million. The unfavorable development in 2009 was due to a $69.8 million increase in reinsurance reserves, primarily related to losses from sub-prime exposures and property lines, and a $59.0 million increase in insurance reserves, primarily related to contractor liability exposures.”

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