WRBW. R. Berkley Corporation

You have fixed maturity securities of $4.8 billion invested in obligations of state and municipal subdivisions that comprised 33% of your total investment portfolio at December 31, 2012. Please provide us the following information:  For special revenue bonds, the nature of the revenue source; and  For any state, municipality or political subdivision that comprised 10 percent or more of the total of your

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investments in obligations of states and political subdivisions, the amortized cost and fair value, and credit rating with and without a financial guarantee by third parties.

As of December 31, 2012, the aggregate carrying value of our special revenue bonds was $2.2 billion. The revenue sources for these bonds were power (18%), transportation (15%), housing

New York Washington Paris London Milan Rome Frankfurt Brussels in alliance with Dickson Minto W.S., London and Edinburgh

Mr. Jim B.

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Rosenberg

(15%), water and sewer (13%), airports (8%), sales tax (7%), universities (6%), special tax (6%) and other (12%).

As of December 31, 2012, no individual state, municipality or political subdivision comprised 10 percent or more of our aggregate investments in obligations of states, municipalities and political subdivisions.

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Please provide proposed disclosure to be provided in future periodic reports that discusses and quantifies the effect that your ceded reinsurance activities had on financial position, results of operations, and cash flows for the periods presented.

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Also discuss changes you have made to your past reinsurance strategies in developing your current strategies and the expected effect that those changes may have on your financial position, results of operations and cash flows. Describe any limitations on your ability to cede future losses on a basis consistent with historical results and their expected effect on financial position, operating results and cash flows. Such limitations could relate to changes in reinsurance market conditions, a restructuring of your reinsurance treaties or the absence of remaining limits for specific accident years under existing treaties. Notes to Consolidated Financial Statements (1) Summary of Significant Accounting Policies (F) Deferred policy acquisition costs, page 67

Please see Appendix A for proposed new disclosures to be included in our Annual Report on Form 10-K, commencing with our 2013 Form 10-K. As reflected in such appendix, the Company’s existing disclosures in the above referenced reinsurance section will be retained. There have not been any material changes in the Company’s reinsurance strategies, nor does the Company believe there are any material limitations on its ability to continue to cede future losses consistent with past practice, that warrant disclosure.

(1) Summary of Significant Accounting Policies

(F) Deferred policy acquisition

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costs, page 67

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Please provide proposed disclosure to be provided in future periodic reports that describes the nature and type of acquisition costs capitalized. Refer to ASC 944-30-50-1. (14) Reinsurance, page 81

to this comment, we will add the following sentence in Note 1(F), Deferred policy acquisition costs to our annual financial statements in our Annual Report on Form 10-K, commencing with our 2013 Form 10-K: “Deferred policy acquisition costs are comprised primarily of commissions, as well as employment-related underwriting costs and premium taxes.”

(14) Reinsurance, page 81 Read in the reply ↗

Please provide proposed disclosure to be provided in future periodic reports that describes the general nature of reinsurance transactions, including a description of the significant types of reinsurance agreements executed. If applicable, include in your proposed disclosure the nature and effect of material nonrecurring reinsurance transactions. Refer to Rule 7-03(a)(13)(c) of Regulation S-X.

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(18) Dividends from Subsidiaries and Statutory Financial Information, page 84

to this comment, we will add the following disclosures to Note 14, Reinsurance in our annual financial statements (changes in italics):

The Company reinsures a portion of its insurance exposures in order to reduce its net liability on individual risks and catastrophe losses. Reinsurance coverage and retentions vary depending on the line of business, location of the risk and nature of loss.

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The Company’s reinsurance purchases include the following:

Property reinsurance treaties - The Company purchases property reinsurance to reduce its exposure to large individual property losses and catastrophe events.

Casualty reinsurance treaties – The Company purchases casualty reinsurance to reduce its exposure to large individual casualty losses, workers’ compensation catastrophe losses and casualty losses involving multiple claimants or insureds.

Facultative reinsurance – The Company also purchases facultative reinsurance on certain individual policies or risks that are in excess of treaty reinsurance capacity.

The Company has not engaged in any material nonrecurring reinsurance transactions and accordingly does not propose to add any further disclosure.

(18) Dividends from Subsidiaries and Statutory Financial Information, page 84

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Please provide proposed disclosure to be provided in future periodic reports that includes the following:  Regarding your disclosures of policyholders’ surplus, revise to explain whether this is the same as statutory capital and surplus as required by ASC 944-505-50-1a;  A definition of the terms RBC Total Adjusted Capital, RBC Authorized Control Level, RBC Company Action Level;  Although you disclose that each

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of your U.S. insurance subsidiaries currently exceeds the minimum required RBC levels, disclose the amount of statutory capital and surplus necessary to satisfy regulatory requirements if significant in relation to actual statutory capital and surplus, as required under ASC 944-505-50-1b. If not significant, please clarify in the disclosure;  Disclose the amounts of restricted net assets for your subsidiaries as of December 31, 2012 or otherwise disclose how you current disclosure complies with the objective in Rule 4-08(e)(3)(ii) of Regulation S-X;  Disclose the amount of retained earnings or net income of W.R. Berkley Corporation that is restricted or free of restrictions for payment of dividends to its stockholders as required by Rule 4-08(e)(1) of Regulation S-X; and,  Provide the disclosures required under ASC 944-505-50-2 through 50-6, as applicable.

to this comment, in the Company’s future annual financial statements, we will also provide the Company’s Total Adjusted Capital and the percentage of such Total Adjusted Capital relative to the RBC Authorized Control Level. See the proposed text in Appendix B.

Disclose the amounts of restricted net assets for your subsidiaries as of December 31, 2012 or otherwise disclose how your current disclosure complies with the objective in Rule 4-08(e)(3)(ii) of Regulation S-X;

Most of the Company’s net assets are held by the Company’s insurance subsidiaries and, accordingly, any distributions from

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these subsidiaries are subject to the regulatory limitations on dividends that could be paid without prior approval. As the Company discloses these limitations and the amount of dividends that are currently available to be paid to the Company in Note 18, Dividends from Subsidiaries and Statutory Financial Information, we do not propose to add any additional disclosure. The Company does not have any other material restrictions on its net assets.

In addition, the Company discloses in Note 3, Investments in Fixed Maturity Securities that certain securities are on deposit as security with state insurance departments, Lloyd’s of London and various reinsurance clients. In response to this comment, in the Company’s future annual financial statements, we will add the following cross-reference in Note 18:

“See Note 3, Investments in Fixed Maturity Securities, for a description of assets held on deposit as security.”

Disclose the amount of retained earnings or net income of W. R. Berkley Corporation that is restricted or free of restrictions for payment of dividends to its stockholders as required by Rule 4-08(e)(1) of Regulation S-X; and

The amount of retained earnings or net income available for payment of dividends to the Company’s stockholders is restricted by regulatory limitations on dividends that could be made to the Company. As noted above, the Company discloses these limitations and the amount of dividends that are currently available to be paid to the Company in Note 18, Dividends from Subsidiaries and Statutory Financial Information, and Note 19, Common Stockholders Equity. Accordingly, the Company does not propose to add any further disclosure.

Provide the disclosures required under ASC 944-505-50-2 through 50-6, as applicable.

In the Company’s future annual financial statements, we will add the following sentence: “The effect of using this permitted practice was to increase BIC’s statutory capital and surplus by $224 million at December 31, 2012.”

Permitted practices are excluded from Total Adjusted Capital and, therefore, do not affect the determination of a regulatory event or the RBC calculations.

Should any member of the Staff have any questions, please do not hesitate to call me at (212) 728-8592.

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