 | VIA EDGAR & FACSIMILE 9th Floor, One Plantation Place | |
CORPORATE CENTRE | 30 Fenchurch Street | |
| London EC3M 3BD | ||
| United Kingdom | ||
| Telephone: | 020 7111 7095 | |
| Fax: | 020 7111 7612 | |
| To: | Jim B Rosenberg |
| Senior Assistant Chief Accountant | |
| Division of Corporate Finance | |
| Securities and Exchange Commission | |
| 450 Fifth Street, NW | |
| Washington, DC 20549 | |
| United States of America | |
| cc: | Frank Wyman, Staff Accountant, Securities and Exchange Commission |
| From: | George Culmer |
| Chief Financial Officer | |
| Royal & Sun Alliance Group plc | |
| Date: | 21 March 2006 Page 1 of 1 |
| Re: | Royal & Sun Alliance 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 March 10, 2006 (“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 March 31, 2006. 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
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Royal & Sun Alliance Insurance Group plc
Registered in England No 2339826. The Registered Office is 9th Floor, One Plantation Place, 30 Fenchurch Street, London EC3M 3BD