June 5, 2006
Ms. Laurie A. Desmet
Chief Accounting Officer
PartnerRe Ltd.
Fifth Floor, Wellesley House South
90 Pitts Bay Road
Pembroke, HM 08, Bermuda

	Re:	PartnerRe Ltd.
      File No. 001-14536

Dear Ms. Desmet:

      In a letter dated May 26, 2006, which you provided in
response
to comments from the Division`s Staff , you request that the staff
not
object if PartnerRe Ltd. excludes the Channel Reinsurance Ltd.
financial statements required by Rule 3-09 of Regulation S-X from
its
Form 10-K for the year ended December 31, 2005.  You note that
PartnerRe acquired its interest in Channel Re in February 2004.
You
also note that the Rule 3-09 investment test for 2004 and 2005 was
deminimus and that the income test significance was only met in
2005,
which in your view was a year of extraordinary large losses
stemming
from Hurricanes Katrina, Rita, and Wilma.  You acknowledge that
the
five year income averaging computational note to Rule 1-02(w) of
Regulation S-X only applies to registrants that have income in
their
most recently completed fiscal year, but you believe the
application
of this computational note shows the true substance of the Channel
Re
investment on PartnerRe`s operations.  You cite the inherent
volatility in the insurance and reinsurance industry and the
significance of the 2005 catastrophic losses as basis for this
belief.
Finally, you note that PartnerRe is considering entering the
capital
markets as soon as market conditions allow and you note the
Staff`s
history of support for the insurance and reinsurance industry in
the
aftermath of catastrophic events, most recently as relates to
companies impacted by Hurricanes Katrina, Rita and Wilma.

      We do not believe the information provided in your letter
provides a sufficient basis for us to grant your request.  In
order to
provide consistent application of Rule 3-09 of Regulation S-X for
all
registrants, we do not permit income averaging for registrants
that
have losses in their most recently completed fiscal year.
Notwithstanding the apparent significance evidenced by this
quantitative test, we have also considered the qualitative factors
you
cited.  While not diminishing in any way the devastating effects
of
these hurricanes, it is not clear that they are one-time events.
Also, insurance and reinsurance loss events are likely to occur
every
period and companies and investors may differ as to which loss
events
involve a "significant and unusual level of losses."  In the
circumstances you describe, we believe fair and consistent
application
of Rule 3-09 can best be achieved by providing financial
statements of
an equity investee when the prescribed significance is met.  We
have
also considered the historical relief you cite, including the
Commission`s September 15, 2005 Order providing emergency
regulatory
relief and the administrative steps announced on October 4, 2005,
but
are unable to discern from your letter the unique facts and
circumstances that would warrant such relief, particularly in
light of
the limited scope and time period to which such relief related.

      If you have any questions regarding this letter, please call
me
at 202.551.3516.

						Sincerely,



						Todd E. Hardiman
						Associate Chief Accountant
Ms. Laurie A. Desmet
Chief Accounting Officer
PartnerRe Ltd.
June 5, 2006
Page 2