December 7, 2005
Via EDGAR and FAX
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549
Attn: | Jim B. Rosenberg |
Senior Assistant Chief Accountant | |
Division of Corporation Finance | |
Re: | Royal & Sun Alliance Insurance Group plc |
Form 20-F for Fiscal Year Ended December 31, 2004 (the “Form 20-F”) | |
File No. 001-15146 |
Dear Mr. Rosenberg:
We received your letter dated November 28, 2005 (the “letter”) in respect of our Form 20-F and we noted the 10 business-day response period set forth therein. We have reviewed the letter and are in the process of preparing a response on an expedited basis. However, in light of the detailed nature of some of the comments, we believe it will be more appropriate to provide a response to the letter by December 19, 2005. We discussed this matter with Frank Wyman, of the SEC staff, who asked that we formally inform you of our position; I trust this is acceptable to you.
Please do not hesitate to contact me at 011 44 20 7111 7117 with any questions.
Yours sincerely,
George Culmer
Chief Financial Officer
cc: Frank Wyman, Staff Accountant, Securities and Exchange Commission