Navigators CORRESP Correspondence with SEC

VIA EDGAR

February 16, 2018

Securities and Exchange Commission

Division of Corporation Finance

Washington, D.C. 20549

Attn:

Jim Rosenberg

Division of Corporation Finance

Office of Healthcare and Insurance

Re:	The Navigators Group, Inc. (the “Company”)

Form 10-K for Fiscal Year Ended December 31, 2016

Filed February 17, 2017

File No. 000-15886

Dear Mr. Rosenberg:

This letter provides additional information in response to the Division of Corporation Finance’s comment letter dated January 5, 2018 (the “Comment Letter”), in which you requested additional information based on your review of the Company’s Annual Report on Form 10-K for the year ended December 31, 2016 (the “2016 10-K”). It is being submitted as a supplement to, and amends in part, the Company’s response letter dated February 5, 2018 (the “Prior Response Letter”) and is based on conversations with the Staff to better clarify and address the matters raised in the Comment Letter. For ease of reference, the comment included in the Comment Letter is repeated below in italicized type, and our response addressing matters raised in subsequent conversations with the Staff immediately follows the comment. Any terms capitalized herein that are not otherwise defined shall have the meaning ascribed to them in the Response Letter.

Notes to Consolidated Financial Statements

Note 5. Reserves for Losses and LAE, page F-22

We acknowledge your response to our prior comment 1 in our November 17, 2017 letter, however, please explain to us why the decrease in estimated losses and LAE for claims occurring in prior years of $28.5 million for 2016 as shown in the table summarizing activity for your reserves for losses and LAE on page F-22 differs significantly from the 2016 loss development implicit in the tables on pages F-25 to F-31, which appear to indicate a net reserve strengthening of $10.3 million. In particular, provide us reconciliations of the 2016 amounts per the table on page F-22 showing the reporting and operating segment breakdowns of prior period net reserve strengthening (releases) to the 2016 reserve development inherent in the tables on pages F-28 to F-31 for each of the three operating segments within the international insurance reporting segment and for the globalre reporting segment.

Supplemental Response:

As noted in the Prior Response Letter, the Company relies on Lloyd’s IT systems to process the business of the Company’s Lloyd’s Syndicate 1221. The Lloyd’s system does not retain claim data by accident year and prior to the adoption of ASU 2015-09, the Company did not retain such data in its own systems. Since ASC 944-40-50-4B was a new requirement for the Company, we thought it was reasonable to use the best information available as of December 31, 2016 to generate the supplemental loss development tables on pages F-28 to F-31. This included information that became known to the Company after a reporting year in the supplemental loss development tables for a claim that occurred in such reporting year.

By using information obtained after a given reporting year, the tables do provide information to users about the pattern of loss emergence over time, but information on variability is eliminated. For instance, for each Syndicate 1221 claim, if

the loss date was available as of a reporting date, we used that date to determine the allocation to accident year. However, if the claim was reported on a bordereau, the specific loss date may not have been initially available, in which case we used policy or report date. These bordereau claims may later mature into a large loss claim, at which point additional information related to the claim, including the loss date, is entered into the system and can be used for the allocation. This could lead to significant differences in the incurred losses reported within the supplemental loss development tables from one reporting period to the next since one claim could appear in a different accident year in a subsequent reporting period.

Upon further consideration, the Company has prepared revised supplemental loss development tables from the available Syndicate 1221 data, which affects the International Marine, International P&C, International Professional Liability and Global Re supplemental loss development tables in Note 5. These supplemental loss development tables were prepared using an alternative allocation process and are attached hereto as Exhibit A, along with additional tables that reflect the difference between the revised supplemental loss development tables and the original supplemental loss development tables in our 2016 10-K.

Under the alternative allocation process, the Company developed a process to allocate the Syndicate 1221 incurred claims to individual prior accident years using only data known at the end of such year. Unlike in our original allocation process, we did not use any information about a particular claim that we obtained after the end of the reporting period in which it was originally reported. This is consistent with what would have been reported in the incurred claims supplemental loss development tables had ASC 944-40-50-4B been effective in those prior reporting periods.

Given our ongoing review of the guidance in ASC 944-40-50-4B, we propose to use this alternative allocation process for the 2015 and prior reporting periods in relation to our Syndicate 1221 business as incorporated in the International Marine, International P&C, International Professional Liability and Global Re supplemental loss development tables in Note 5. While our original allocation process provided information regarding the systematic nature of loss emergence, this alternative process provides a closer estimate of loss development as presented in the table on page F-22 of the 2016 10-K, as demonstrated by the reconciliation tables attached hereto as Exhibit B, and also provides additional information on variability for the specific reporting segment as each accident year matures. We note that we have not made any changes to the net paid claims supplemental loss development tables in our 2016 10-K.

Additionally, to provide the users of the financial statements with an understanding of the effect of the limitations of the data from our Syndicate 1221 business for the reporting years 2015 and prior in the supplemental loss development tables, as well as the allocation process we used for those reporting years, we have included updated proposed disclosure for Note 5 attached hereto as Exhibit C. We also reiterate, as stated in the Prior Response Letter, the process the Company currently has in place to capture and retain more detailed data for the reporting years 2016 and forward will eliminate any discrepancies going forward between the rollforward table on page F -22 and the supplemental loss development tables.

We welcome the opportunity to discuss any of the information included herein should you desire. If you have any questions or comments concerning this response letter, please contact the undersigned at (203) 905-6343 (cdefalco@navg.com) or Emily Miner at (203) 905-6369 (eminer@navg.com).

Respectfully submitted,

The Navigators Group, Inc.

By:

/s/ Ciro M. DeFalco

Name:

Ciro M. DeFalco

Title:

Executive Vice President and Chief Financial Officer

EXHIBIT A

	Int'l Marine
	Loss and ALAE, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,																														As of December 31, 2016
AY																2012			2013			2014			2015			2016			Total IBNR			# of Reported Claims
2007																$	68,144		$	64,769		$	66,428		$	66,553		$	66,239			(35	)		5,585
2008																	83,790			79,453			79,228			82,747			82,752			98			5,809
2009																	93,980			89,241			88,108			81,210			79,526			111			4,969
2010																	127,263			126,234			115,709			111,426			108,405			282			5,317
2011																	95,941			82,285			78,988			74,621			70,751			25			4,824
2012																	106,216			126,893			104,340			97,037			90,523			(216	)		5,201
2013																				82,880			89,756			77,717			77,239			747			5,075
2014																							94,559			108,983			107,789			(1,500	)		4,928
2015																										94,227			91,371			5,194			6,967
2016																													84,156			26,285			5,577
																									Total			$	858,751


	Int'l Marine
	Cumulative Paid Claims and Allocated Claim Adjustment Expenses, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,
AY																2012			2013			2014			2015			2016
2007																$	59,831		$	60,702		$	61,956		$	62,729		$	63,281
2008																	69,959			72,309			73,746			77,535			78,683
2009																	64,058			68,085			70,834			74,311			75,006
2010																	74,920			87,186			93,167			97,132			99,416
2011																	43,740			56,569			60,879			65,580			66,538
2012																	22,777			52,968			68,498			76,572			79,205
2013																				21,703			42,953			54,826			60,828
2014																							24,445			50,168			73,921
2015																										22,323			52,356
2016																													22,193
																									Total			$	671,426
																									Net reserves < 2007				9,207
																									Total Net reserves			$	196,532


	Int'l Marine
	Average Annual Percentage Payout of Incurred Claims by Age, Net of Reinsurance
Years	1			2			3			4			5			6			7			8			9			10
Int'l Marine		24.5	%		28.1	%		18.2	%		7.6	%		5.0	%		2.8	%		2.7	%		2.4	%		1.3	%		0.8	%

	Int'l P&C
	Loss and ALAE, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,																														As of December 31, 2016
AY																2012			2013			2014			2015			2016			Total IBNR			# of Reported Claims
2007																$	30,898		$	30,902		$	30,860		$	31,215		$	25,778			(60	)		584
2008																	32,170			29,495			29,497			29,027			36,729			(75	)		891
2009																	31,940			31,792			31,847			31,755			25,113			13			743
2010																	38,276			37,375			36,928			37,417			38,198			58			836
2011																	63,754			55,344			53,296			53,718			52,202			(198	)		833
2012																	36,934			30,321			29,566			27,821			27,828			(353	)		877
2013																				33,461			32,799			33,035			29,684			(308	)		1,229
2014																							25,235			17,877			17,006			173			1,167
2015																										27,320			30,932			2,106			1,678
2016																													75,571			13,006			2,646
																									Total			$	359,041


	Int'l P&C
	Cumulative Paid Claims and Allocated Claim Adjustment Expenses, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,
AY																2012			2013			2014			2015			2016
2007																$	23,885		$	24,681		$	25,150		$	25,292		$	25,289
2008																	34,084			35,161			35,463			35,975			35,826
2009																	23,371			24,257			24,713			24,286			24,369
2010																	32,156			36,499			39,017			36,509			36,601
2011																	33,316			42,280			45,125			47,591			48,502
2012																	7,884			15,648			20,850			24,871			26,049
2013																				6,829			17,613			24,735			27,180
2014																							3,813			8,458			12,304
2015																										6,739			18,096
2016																													24,256
																									Total			$	278,471
																									Net reserves < 2007				620
																									Total Net reserves			$	81,189


	Int'l P&C
	Average Annual Percentage Payout of Incurred Claims by Age, Net of Reinsurance
Years	1			2			3			4			5			6			7			8			9			10
Int'l P&C		25.4	%		33.5	%		21.8	%		9.4	%		5.2	%		-1.0	%		-0.2	%		1.2	%		0.1	%		0.0	%

	Int'l Professional Liability
	Loss and ALAE, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,																														As of December 31, 2016
AY																2012			2013			2014			2015			2016			Total IBNR			# of Reported Claims
2007																$	21,270		$	13,155		$	13,593		$	13,670		$	12,381			(64	)		235
2008																	11,617			13,350			13,585			13,591			14,023			(175	)		365
2009																	16,475			17,006			17,100			16,726			15,780			629			445
2010																	14,266			13,845			14,009			13,978			15,619			1,409			653
2011																	15,221			17,893			19,130			8,769			6,835			356			681
2012																	6,761			11,359			12,595			13,241			16,891			490			718
2013																				9,965			4,040			14,283			15,402			4,255			1,053
2014																							20,357			24,112			23,457			12,421			1,276
2015																										27,871			30,104			17,379			1,939
2016																													36,006			31,814			2,554
																									Total			$	186,498


	Int'l Professional Liability
	Cumulative Paid Claims and Allocated Claim Adjustment Expenses, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,
AY																2012			2013			2014			2015			2016
2007																$	11,293		$	11,704		$	12,269		$	12,277		$	12,382
2008																	12,150			13,306			13,702			13,732			14,019
2009																	8,805			10,716			12,783			13,803			14,118
2010																	5,801			7,169			10,460			12,632			13,366
2011																	1,197			2,002			2,950			4,007			4,576
2012																	2,133			3,219			4,253			5,483			7,365
2013																				725			2,196			2,952			9,230
2014																							1,368			2,421			5,068
2015																										3,355			5,765
2016																													2,012
																									Total			$	87,901
																									Net reserves < 2007				92
																									Total Net reserves			$	98,689


	Int'l Professional Liability
	Average Annual Percentage Payout of Incurred Claims by Age, Net of Reinsurance
Years	1			2			3			4			5			6			7			8			9			10
Int'l Professional Liability		7.5	%		7.3	%		7.4	%		20.6	%		15.9	%		11.8	%		4.7	%		2.3	%		1.1	%		0.8	%

	GlobalRe
	Loss and ALAE, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,																														As of December 31, 2016
AY							2009			2010			2011			2012			2013			2014			2015			2016			Total IBNR			# of Reported Claims
2007								-			-			-		$	5,915		$	5,730		$	5,917		$	5,771		$	5,883			(141	)		254
2008								0			0			0			14,231			14,585			13,952			13,551			13,298			672			294
2009								4,970			3,734			3,752			11,125			11,247			11,136			10,398			10,475			204			202
2010											3,743			3,500			12,993			12,942			13,957			11,762			12,330			(1,000	)		195
2011														39,678			53,748			76,225			76,020			73,503			72,667			(461	)		766
2012																	107,083			98,992			92,552			88,153			114,728			531			1,419
2013																				114,724			118,644			102,474			104,913			3,973			1,185
2014																							119,288			141,922			121,535			9,825			920
2015																										101,557			91,098			11,623			680
2016																													88,192			38,785			335
																									Total			$	635,119


	GlobalRe
	Cumulative Paid Claims and Allocated Claim Adjustment Expenses, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,
AY							2009			2010			2011			2012			2013			2014			2015			2016
2007								-			-			-		$	5,225		$	5,275		$	5,345		$	5,357		$	5,350
2008								0			0			0			11,629			11,650			11,510			11,488			11,546
2009								0			3,734			3,752			8,620			8,853			8,974			9,932			10,045
2010											0			3,490			9,875			10,213			10,387			11,009			11,062
2011														4,160			43,342			71,010			71,677			71,954			72,094
2012																	37,644			77,077			83,183			84,533			111,681
2013																				53,375			82,558			90,567			98,271
2014																							66,249			119,136			105,505
2015																										41,620			64,316
2016																													36,254
																									Total			$	526,123
																									Net reserves < 2007				2,599
																									Total Net reserves			$	111,594


	GlobalRe
	Average Annual Percentage Payout of Incurred Claims by Age, Net of Reinsurance
Years	1			2			3			4			5			6			7			8			9			10
GlobalRe		47.1	%		32.1	%		0.6	%		3.1	%		8.5	%		2.1	%		2.8	%		0.7	%		0.3	%		-0.1	%

	Int'l Marine- Comparison of Revised and 2016 Submitted
	Loss and ALAE, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,																														As of December 31, 2016
AY																2012			2013			2014			2015			2016			Total IBNR		# of Reported Claims
2007																	(2,489	)		(2,379	)		(523	)		(329	)		-			-		-
2008																	(4,930	)		(5,832	)		(4,902	)		(1,444	)		0			0		-
2009																	4,923			2,327			3,610			(886	)		0			0		-
2010																	3,545			7,214			1,521			(43	)		0			0		-
2011																	4,594			(4,510	)		116			(1,252	)		0			0		-
2012																	12,520			10,958			4,658			2,151			0			0		-
2013																				14,293			7,443			(2,996	)		0			0		-
2014																							9,047			3,911			0			0		-
2015																										23,552			0			0		-
2016																													0			0		-
																									Total				-


	Int'l Marine
	Cumulative Paid Claims and Allocated Claim Adjustment Expenses, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,
AY																2012			2013			2014			2015			2016
2007																	-			-			-			-			-
2008																	0			0			0			0			0
2009																	0			0			0			0			0
2010																	0			0			0			0			0
2011																	0			0			0			0			0
2012																	0			0			0			0			0
2013																				0			0			0			0
2014																							0			0			0
2015																										0			0
2016																													0
																									Total				-
																									Net reserves < 2007				0
																									Total Net reserves				-


	Int'l Marine
	Average Annual Percentage Payout of Incurred Claims by Age, Net of Reinsurance
Years	1			2			3			4			5			6			7			8			9			10
Int'l Marine		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%

	Int'l P&C- Comparison of Revised and 2016 Submitted
	Loss and ALAE, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,																														As of December 31, 2016
AY																2012			2013			2014			2015			2016			Total IBNR		# of Reported Claims
2007																$	4,814		$	5,085		$	5,120		$	5,359			-			-		-
2008																	(7,333	)		(8,389	)		(8,370	)		(8,268	)		0			0		-
2009																	5,440			5,988			5,938			6,337			0			0		-
2010																	(805	)		(2,034	)		(2,121	)		(1,614	)		0			0		-
2011																	6,291			1,689			1,203			1,052			0			0		-
2012																	2,454			(322	)		(781	)		(805	)		0			0		-
2013																				3,966			(922	)		1,985			0			0		-
2014																							5,001			890			0			0		-
2015																										906			0			0		-
2016																													0			0		-
																									Total				-


	Int'l P&C
	Cumulative Paid Claims and Allocated Claim Adjustment Expenses, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,
AY																2012			2013			2014			2015			2016
2007																	-			-			-			-			-
2008																	0			0			0			0			0
2009																	0			0			0			0			0
2010																	0			0			0			0			0
2011																	0			0			0			0			0
2012																	0			0			0			0			0
2013																				0			0			0			0
2014																							0			0			0
2015																										0			0
2016																													0
																									Total				-
																									Net reserves < 2007				0
																									Total Net reserves				-


	Int'l P&C
	Average Annual Percentage Payout of Incurred Claims by Age, Net of Reinsurance
Years	1			2			3			4			5			6			7			8			9			10
Int'l P&C		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%

	Int'l Professional Liability- Comparison of Revised and 2016 Submitted
	Loss and ALAE, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,																														As of December 31, 2016
AY																2012			2013			2014			2015			2016			Total IBNR		# of Reported Claims
2007																$	8,369		$	568		$	1,148		$	1,292			-			-		-
2008																	(3,895	)		(1,951	)		(1,231	)		(420	)		0			0		-
2009																	1,666			1,639			2,128			437			0			0		-
2010																	(4,337	)		(2,314	)		(1,652	)		(3,473	)		0			0		-
2011																	5,535			10,245			12,005			1,719			0			0		-
2012																	(1,443	)		1,607			3,488			2,066			0			0		-
2013																				(5,131	)		(13,588	)		(1,989	)		0			0		-
2014																							1,523			43			0			0		-
2015																										5,111			0			0		-
2016																													0			0		-
																									Total				-


	Int'l Professional Liability
	Cumulative Paid Claims and Allocated Claim Adjustment Expenses, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,
AY																2012			2013			2014			2015			2016
2007																	-			-			-			-			-
2008																	0			0			0			0			0
2009																	0			0			0			0			0
2010																	0			0			0			0			0
2011																	0			0			0			0			0
2012																	0			0			0			0			0
2013																				0			0			0			0
2014																							0			0			0
2015																										0			0
2016																													0
																									Total				-
																									Net reserves < 2007				0
																									Total Net reserves				-


	Int'l Professional Liability
	Average Annual Percentage Payout of Incurred Claims by Age, Net of Reinsurance
Years	1			2			3			4			5			6			7			8			9			10
Int'l Professional Liability		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%

	GlobalRe- Comparison of Revised and 2016 Submitted
	Loss and ALAE, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,																														As of December 31, 2016
AY							2009			2010			2011			2012			2013			2014			2015			2016			Total IBNR		# of Reported Claims
2007								0			0			0			(300	)		(460	)		(255	)		(119	)		0			0		0
2008								0			0			0			368			561			421			247			0			0		0
2009								0			0			0			(61	)		(133	)		391			8			0			0		0
2010											0			0			(463	)		(720	)		1,059			165			0			0		0
2011														0			2,916			2,094			2,509			461			0			0		0
2012																	(1,707	)		(4,191	)		(2,213	)		(900	)		0			0		0
2013																				1,989			(368	)		771			0			0		0
2014																							(1,191	)		815			0			0		0
2015																										1,683			0			0		0
2016																													0			0		0
																									Total				0


	GlobalRe
	Cumulative Paid Claims and Allocated Claim Adjustment Expenses, Net of Reinsurance
amounts in thousands	For the Years Ended December 31,
AY							2009			2010			2011			2012			2013			2014			2015			2016
2007								-			-			-			-			-			-			-			-
2008								0			0			0			0			0			0			0			0
2009								0			0			0			0			0			0			0			0
2010											0			0			0			0			0			0			0
2011														0			0			0			0			0			0
2012																	0			0			0			0			0
2013																				0			0			0			0
2014																							0			0			0
2015																										0			0
2016																													0
																									Total				-
																									Net reserves < 2007				0
																									Total Net reserves				-


	GlobalRe
	Average Annual Percentage Payout of Incurred Claims by Age, Net of Reinsurance
Years	1			2			3			4			5			6			7			8			9			10
GlobalRe		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%		0.0	%

EXHIBIT B The Navigators Group, Inc
Reconciliation of Short Duration Triangles
SEC Comment Letter FY 2016
($ amounts in thousands)			2016
	Item	2016 10-K Reference	Int'l Marine			Int'l P&C			Int'l Prof Liab			GlobalRe
Current AY Incurred Per Financial Statement Rollforward Table	2016 Total Loss Incurred	pages 37, 38 and 41	$	67,051		$	68,995		$	42,238		$	89,304
	Prior AY Loss Incurred	page F-22	$	(22,068	)	$	(7,051	)	$	4,100		$	(2,161	)
	Current AY Loss Incurred		$	89,119		$	76,046		$	38,138		$	91,465
Reconciling Items:	Less: ULAE Excluded from Triangles		$	2,601		$	1,604		$	1,157		$	1,310
	Less: Foreign Exchange and Other⁽¹⁾		$	2,362		$	(1,129	)	$	975		$	1,963
Adjusted Balance			$	84,156		$	75,571		$	36,006		$	88,192
2016 Current AY Incurred Per Short-Duration Triangle Disclosures	2016 Current AY Incurred	Proposed pages F-25 through F-31	$	84,156		$	75,571		$	36,006		$	88,192


Current AY Incurred Per Financial Statement Rollforward Table	Prior AY Incurred	page F-22	$	(22,068	)	$	(7,051	)	$	4,100		$	(2,161	)
Reconciling Items:	Less: Foreign Exchange and Other⁽¹⁾		$	(2,142	)	$	(1,336	)	$	(152	)	$	2
2016 Current AY Incurred Per Short-Duration Triangle Disclosures	Change in Prior AY Incurred	Proposed pages F-25 through F-31	$	(19,926	)	$	(5,715	)	$	4,252		$	(2,163	)

			2015
	Item	2016 10-K Reference	Int'l Marine			Int'l P&C			Int'l Prof Liab		GlobalRe
Current AY Incurred Per Financial Statement Rollforward Table	2015 Total Incurred	pages 37, 38 and 41	$	79,737		$	20,478		$	34,487	$	94,399
	Prior AY Incurred	page F-22	$	(21,914	)	$	(8,458	)	$	4,156	$	(9,134	)
	Current AY Incurred		$	101,651		$	28,936		$	30,331	$	103,533
Reconciling Items:	Less: ULAE Excluded from Triangles		$	2,812		$	749		$	1,138	$	1,279
	Less: Foreign Exchange and Other⁽¹⁾		$	4,612		$	867		$	1,322	$	697
Adjusted Balance			$	94,227		$	27,320		$	27,871	$	101,557
2016 Current AY Incurred Per Short-Duration Triangle Disclosures	2015 Current AY Incurred	Proposed pages F-25 through F-31	$	94,227		$	27,320		$	27,871	$	101,557


Current AY Incurred Per Financial Statement Rollforward Table	Prior AY Incurred	page F-22	$	(21,914	)	$	(8,458	)	$	4,156	$	(9,134	)
Reconciling Items:	Less: Foreign Exchange and Other⁽¹⁾		$	(5,092	)	$	(295	)	$	195	$	(5,201	)
2016 Current AY Incurred Per Short-Duration Triangle Disclosures	Change in Prior AY Incurred	Proposed pages F-25 through F-31	$	(16,822	)	$	(8,163	)	$	3,961	$	(3,933	)

			2014
	Item	2016 10-K Reference	Int'l Marine			Int'l P&C			Int'l Prof Liab			GlobalRe
Current AY Incurred Per Financial Statement Rollforward Table	2014 Total Incurred	pages 37, 38 and 41	$	71,986		$	23,317		$	19,776		$	118,311
	Prior AY Incurred	page F-22	$	(31,677	)	$	(3,829	)	$	(2,746	)	$	(2,140	)
	Current AY Incurred		$	103,663		$	27,146		$	22,522		$	120,451
Reconciling Items:	Less: ULAE Excluded from Triangles		$	2,518		$	1,205		$	720		$	734
	Less: Foreign Exchange and Other⁽¹⁾		$	6,586		$	706		$	1,445		$	429
Adjusted Balance			$	94,559		$	25,235		$	20,357		$	119,288
2014 Current AY Incurred Per Short-Duration Triangle Disclosures	2014 Current AY Incurred	Proposed pages F-25 through F-31	$	94,559		$	25,235		$	20,357		$	119,288


Current AY Incurred Per Financial Statement Rollforward Table	Prior AY Incurred	page F-22	$	(31,677	)	$	(3,829	)	$	(2,746	)	$	(2,140	)
Reconciling Items:	Less: Foreign Exchange and Other⁽¹⁾		$	(2,479	)	$	68		$	(224	)	$	126
2014 Current AY Incurred Per Short-Duration Triangle Disclosures	Change in Prior AY Incurred	Proposed pages F-25 through F-31	$	(29,198	)	$	(3,897	)	$	(2,522	)	$	(2,266	)


* Other includes any activity on 2006 and prior Accident Years which is not displayed on the triangle.

EXHIBIT C

Note 5. Reserves for Losses and LAE – Page F-24

The information provided in our supplemental tables related to short duration contracts includes estimates. Prior to the 2016 calendar year, records for Syndicate 1221 were not available by individual Accident Year (AY), which impacts the presentation of our Int’l Insurance and, to a limited extent, our Global Re supplemental tables for 2015 and prior reporting years. For this 2017 calendar year report, we revised and improved the allocation process used in our 2016 presentation in relation to our Syndicate 1221 business. For the 2016 calendar year report, we applied an allocation process using inception to date gross paid and case information through 2016 to extrapolate the data for reporting years 2012 through 2015 in our supplemental tables. Upon further consideration, for 2017 reporting, the Company developed a process to allocate the Syndicate 1221 incurred claims to individual prior accident years using only data known as of the end of such year.

While the estimation process used in 2016 provided information regarding the systematic nature of loss emergence, the revised and improved process applied in the current calendar year more accurately reflects information on variability of loss emergence from period to period. We believe that this process is more aligned with the objectives of this disclosure, and the total amounts reported in the rollforward table in Note 5. Beginning in the 2016 calendar year, the Company implemented a process for the business underwritten through Syndicate 1221 that captures and retains more detailed incurred claim data to enable it to assign AY information as accurately and completely as possible using the data available.

In addition, due to the limitations of the data available for our Syndicate 1221 business, the supplemental tables below for our Int’l Insurance reporting segment begin with the 2012 reporting year and will increase by one year until ten years are presented. Our GlobalRe reporting segment’s supplemental tables do not have data prior to the 2009 reporting year, as we began our assumed reinsurance GlobalRe initiative in 2010. A small portion of business written by Syndicate 1221 in calendar year 2009 was allocated to the reporting segment.

Navigators (NAVG) Inactive CORRESPCorrespondence with SEC