April 11, 2012
Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
United States Securities and Exchange Commission
Division of Corporate Finance
Mail Stop 6010
100 F Street, N.E.
Washington, D.C. 20549
Re: | Affirmative Insurance Holdings, Inc. |
Form 10-K for Fiscal Year Ended December 31, 2010
Filed March 31, 2011
File No. 000-50795
Dear Mr. Rosenberg:
This letter regards the Commission’s October 25, 2011 comment letter (the “Comment Letter”), with respect to the Form 10-K for the year ended December 31, 2010, of Affirmative Insurance Holdings, Inc. (“Affirmative”). Affirmative filed its initial response to the Comment Letter on November 21, 2011 (“November Response”). On December 28, 2011, the Commission Staff (“Staff”) provided Affirmative with verbal comments on the November Response. On January 26, 2012, Affirmative filed its response to the Staff’s verbal comments (the “January Response”). The Commission subsequently provided further comment via correspondence dated February 16, 2012 (the “February Letter”), to which Affirmative responded in writing on March 16, 2012 (the “March Response”).
On March 28, 2012, the Staff provided verbal comments on the March Response to Affirmative and requested Affirmative’s written response within ten (10) business days, i.e. on or before April 11, 2012.
To ensure that Affirmative has sufficient time to respond appropriately to the Staff’s comments, we request an additional ten (10) business days to provide our written response. Accordingly, this correspondence will confirm that Affirmative intends to submit a written response to the Staff on or beforeWednesday, April 25, 2012.
Thank you for your attention to this matter. If you have any questions or comments, please do not hesitate to contact the undersigned.
Sincerely,
/s/ Michael J. McClure
Michael J. McClure
Executive Vice President &
Chief Financial Officer
Affirmative Insurance Holdings, Inc.
4450 Sojourn Drive, Suite 500
Addison, Texas 75001
Telephone: (630) 560-7205
Facsimile: (630) 560-7013
E-Mail:michael.mcclure@affirmativeinsurance.com