WRBW. R. Berkley Corporation

We have not yet reviewed the Part III information that is incorporated by reference into your Form 10-K. We may have further comments after reviewing that information and we will not be able to clear our review of your filing until we have the opportunity to resolve any resulting comments. Notes to the Consolidated Financial Statements (13) Fair Value Measurement, page 71

The above is acknowledged.

Notes to the Consolidated Financial Statements

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Refer to your disclosure of fixed maturity securities herein and in Notes (4) and (12). It is not clear to us why further disaggregation of your fixed maturity securities is not warranted. Please provide us analyses under ASC 320-10-50-1B and 820 -10-50-2B supporting your determination of “major security types” and “classes” of securities that you present.

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In this regard, tell us your basis for the disaggregation of fixed maturity securities in the table on page 46 under “Investments.”

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Mr. Jim B. Rosenberg

Following receipt of this comment, Berkley evaluated whether further disaggregation of the categories of its fixed maturity securities was necessary. Upon completion of this evaluation, Berkley continues to believe that the categories of investments provided in notes 4, 12 and 13 properly reflect the nature and risks of its investment portfolio and need not be disaggregated further, as the securities within those categories do not differ significantly

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in their nature or risks, e.g., vintage, geographic concentration or credit quality. The Company has further disaggregated these fixed maturity securities in its disclosure on page 46, as it believes that this additional detail regarding the composition of its investment portfolio may be useful to investors in understanding concentrations in its fixed maturity securities portfolio. Accordingly, no change to the tables included in the above-referenced notes is proposed. However, the Company will continue to monitor the composition of its fixed maturity security portfolio and include further disaggregation in future filings if warranted.

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Refer to the second paragraph herein as applicable to your level 2 fixed maturity securities. You indicate that you use “pricing models and processes.” You also indicate that the “Company determines fair value based on independent broker quotations and other observable market data.” These disclosures do not describe the valuation technique(s) you use to determine fair value.

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Please provide us, for each “class” (see comment one above) 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. (14) Reserves for Losses and Loss Expenses, page 74

In light of the Staff’s comment, the Company will provide expanded disclosure regarding the valuation techniques and inputs it used to determine fair value, as set forth in Appendix A hereto (replacing the current first two paragraphs at the beginning of the Fair Value Measurements note). This enhanced disclosure will be provided commencing with Berkley’s next Quarterly Report on Form 10-Q.

The Company notes that a detailed description of its use of various pricing sources, including independent pricing services (which accounted for 97.3% of its level 2 fixed maturity security portfolio as

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of December 31, 2014), is included on page 37. After considering the Staff’s comment, the Company intends to enhance its disclosure (commencing with its next Quarterly Report on Form 10-Q) to provide further detail by class as to the specific pricing source used. See our proposed disclosure attached as Appendix B. The Company believes that this new disclosure, together with the descriptions of the various pricing sources and the proposed enhanced description set forth in Appendix A, provides investors with the necessary information to understand its fair value measurement of these level 2 securities by class, but that further disaggregation is not required, for the reasons described above.

(14) Reserves for Losses and Loss Expenses, page 74

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Please tell us how your discounting of reserves for the non-proportional business complies with Staff Accounting Bulletin Topic 5.N., which suggests that discounting be limited to “settled claims” in which “the payment pattern and ultimate cost are fixed and determinable on an individual claim basis.”

The Company discounts its liabilities for excess and assumed workers’ compensation (“EWC”) business. These liabilities are discounted for reporting to state regulatory authorities and for generally accepted accounting principles. Almost all (approximately 90% in 2014) of the discount is related to business written by Midwest Employers Casualty Company (“MECC”), a Company subsidiary, with the balance relating to other business that is discounted for statutory reporting purposes.

Berkley’s discounting policy for EWC reserves was accepted by the Staff following discussions and correspondence

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with MECC in 1993 in connection with a contemplated initial public offering by MECC (which was subsequently withdrawn due to market conditions). Upon its acquisition of MECC in 1995, Berkley continued MECC’s discounting policy for its EWC reserves, as described in such correspondence. This policy, following a comment from the Staff, was again accepted by the Staff in 2001. The nature of MECC’s business and liabilities remains the same as it was at the time of the discussions and correspondence with the Staff in 1993 and 2001.

For your convenience, we are providing to Mr. Sundwall of the Staff concurrently with this response letter, on a supplemental basis, copies of this 1993 and 2001 correspondence between the Staff and MECC and Berkley relating to their discounting policies and their compliance with SAB Topic 5.N. The nature of Berkley and MECC’s EWC business and liabilities remains the same as it was at the time of these discussions and correspondence with the Staff in 1993 and 2001 and accordingly has remained the Company’s longstanding policy.

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

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Refer to your response to our prior comment 2. Please expand your analyses under ASC 320-10-50-1B and ASC 820-10-50-2B provided in your response to our prior comment 1 to further support your determination of “major security types” and “classes” of fixed maturity securities herein and in Notes 4 and 12.

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In this regard, your disclosure on page 46 shows significant concentrations within state and municipal of special revenue fixed maturity securities and within corporate of asset-backed fixed maturity securities. Help us understand why these disclosures are material yet further disaggregation under ASC 320-10-50-1B and ASC 820-10-50-2B is not necessary. Also, compare and analyze the risks and economics between your special revenue versus your other state and municipal fixed maturity securities, and between your asset-backed corporate versus your other corporate fixed maturity securities.

As requested, commencing with its upcoming Quarterly Report on Form 10-Q, Berkley will disaggregate the disclosures for state and municipal bonds and corporate bonds included in note

Mr. Jim B. Rosenberg

4, Investments in Fixed Maturity Securities (with respect to the Company’s available for sale securities),1 consistent with its disaggregated presentation of these asset classes in its Management’s Discussion and Analysis section on page 46 of its 2014 Form 10-K.

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With this expanded presentation in note 4 (the first relevant note in the financial statements), we do not intend to repeat this disaggregated presentation in notes 12 and 13.

With this expanded presentation, Berkley does not believe that any further discussion of the risks and economics of its special revenue securities portfolio versus its other state and municipal fixed maturity securities, or of its asset-backed corporate securities versus its other corporate fixed maturity securities, is needed.

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We have reviewed your proposed disclosure in response to our prior comment 3 and are not clear how it meets the disclosure objective in ASC 820-10-50-2bbb. As previously requested, please provide us, for each “class” of level 2 fixed maturity securities, the valuation technique(s) and inputs used in your fair value measurement.

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To the extent that you use more than one technique in a class, tell us:  the extent to which you use each technique for the class;  what determines when each technique is used in the class; and  the inputs for each technique in the class. (14) Reserves for Losses and Loss Expenses, page 74

As noted in our previous response letter of May 14, 2015, in light of the Staff’s comment, the Company will provide expanded disclosure in note 13, Fair Value Measurements regarding the valuation techniques and inputs it used to determine fair value, as set forth in Appendix A hereto (replacing the current first two paragraphs at the beginning of the note).

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(Note that Appendix A attached to this letter includes some further enhancements to that included with our previous response letter.) This enhanced disclosure will be provided commencing with Berkley’s upcoming Quarterly Report on Form 10-Q.

The Company notes that an independent pricing service is used to value substantially all (98.5% at March 31, 2015) of the Company’s fixed maturity securities. After further considering the Staff’s comment and analyzing the various pricing techniques used by the independent pricing service, the Company verified that the pricing techniques used by this service do not differ among the subclasses of the Company’s Level 2 fixed maturity securities; instead, the determination of which specific techniques the pricing service uses for a given security at any particular time is based primarily upon the characteristics of the specific security and the availability of data, rather than on the class or subclass of security.2 Accordingly, the Company believes that its current disclosure (as proposed to be enhanced) appropriately

1 The Company’s held to maturity securities are currently not material; the Company would include a disaggregated presentation of these securities if, in the future, the amounts involved become material.

2 To clarify this, our proposed enhanced disclosure would state: The pricing services may prioritize inputs differently on any given day for any security based on market conditions, and not all inputs are available for each security evaluation on any given day. See Appendix A.

describes the pricing techniques used by the pricing service to value the Company’s Level 2 fixed maturity securities.

(14) Reserves for Losses and Loss Expenses, page 74

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We have reviewed your response to our prior comment 4. Please provide us proposed disclosure to be included in future periodic reports that includes the following:  The amount of your reserves that are discounted and the percentage represented by non-proportional versus proportional.  The reason that you do not use the statutory rates to discount the non-proportional reserves.

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 That the risk-free rate used for non-proportional is determined annually reflecting a weighted average rate for the period, once established no adjustments are made for that period, and subsequent adjustments for those reserves are discounted at the same rate regardless of when the adjustment is recognized.

In light of the Staff’s comment, the Company will provide the below enhanced disclosure in note 14, Reserves for Losses and Loss Expenses, commencing with its next Annual Report on Form 10-K (updated as appropriate). (In this revised disclosure, to improve readability, the Company replaced the previous references to proportional/non-proportional business with more descriptive language.)

The Company discounts its liabilities for certain workers’ compensation reserves.

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The amount of workers’ compensation reserves that were discounted was $2,187 million and $2,308 million at December 31, 2014 and 2013, respectively. The aggregate net discount for those reserves, after reflecting the effects of ceded reinsurance, was $746 million and $837 million at December 31, 2014 and 2013, respectively. At December 31, 2014, discount rates by year ranged from 2.0% to 6.5%, with a weighted average discount rate of 4.2%.

The majority of discounted workers’ compensation reserves (98% of total discounted reserves at December 31, 2014) are excess workers’ compensation reserves. In order to properly match loss expenses with income earned on investment securities supporting the liabilities, reserves for excess workers’ compensation business are discounted using risk-free discount rates determined by reference to the U.S. Treasury yield curve. These rates are determined annually based on the weighted average rate for the period. Once established, no adjustments are made to the discount rate for that period, and any increases or decreases in loss reserves in subsequent years are discounted at the same rate, without regard to when any such adjustments are recognized. The expected loss and loss expense payout patterns subject to discounting are derived from the Company’s loss payout experience.

The Company also discounts reserves for certain other long-duration workers’ compensation reserves (representing approximately 2% of total discounted reserves at December 31, 2014), including reserves for quota share reinsurance and reserves related to losses regarding occupational lung disease. These reserves are discounted at statutory rates permitted by the Department of Insurance of the State of Delaware.

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

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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

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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.”

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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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