UNITED STATES
                                 SECURITIES AND EXCHANGE COMMISSION
                                             WASHINGTON, D.C. 20549


    DIVISION OF
CORPORATION FINANCE


                                                                       April 4,
2019

  Craig S. Comeaux
  Secretary
  Argo Group International Holdings, Ltd.
  110 Pitts Bay Road
  Pembroke HM 08, Bermuda

          Re:     Argo Group International Holdings, Ltd.
                  PRER14A preliminary proxy statement filing made on Schedule
14A
                  Filed on April 4, 2019 by Argo Group International Holdings,
Ltd.
                  File No. 001-15259

  Dear Mr. Comeaux,

          We have reviewed the above-captioned filing, and have the following
comments. Some
  of our comments may ask for additional information so that we may better
understand the disclosure.

           Please respond to this letter by amending the filing and/or by
providing the requested
  information. If you do not believe our comments apply to your facts and
circumstances, and/or do
  not believe an amendment is appropriate, please tell us why in a written
response.

          After reviewing any amendment to the filing and any information
provided in response to
  these comments, we may have additional comments.

  Schedule 14A

  Corporate Governance, Committees and Meetings of the Board of Directors, page
13

  1. Argo represents that it "regularly rotates the Chair of [its] committees."
Please advise us,
     with a view toward revised disclosure, of the names of the Chair of each
Committee named
     in this section as well as the names of the two previous individuals to
hold those positions.

  Compensation Discussion and Analysis, page 63

  2. Argo states that "[i]n conjunction with the renegotiation and renewal of
Mr. Watson's
     employment agreement in November of 2018, the Board determined that Mr.
Watson would
     no longer be eligible to receive housing and home leave and travel
allowances effective
     January 1, 2019." Please advise us of the basis of the participants'
conclusion that Mr.
     Watson is "no longer eligible" to receive such benefits. For example,
please explain, with a
     view toward revised disclosure, if a prior document authorized or
otherwise provided for
     housing, home leave and travel allowances, and if so, the name of such
document.
 Craig S. Comeaux
Argo Group International Holdings, Ltd.
April 4, 2019
Page 2

Annex C | Supplemental Information Regarding Participants, page C-1

Company Securities Purchased or Sold, page C-2

3. While we recognize that, pursuant to Rule 14a-5(a), negative responses to
line items need not
   be disclosed in the proxy statement, certain publicly available information,
particularly that
   which is reported under  16, suggests some information required by Item
5(b)(1) of Schedule
   14A may have been inadvertently omitted. Please confirm that the
participants' transaction
   histories are consistent with the information reported on Form 4, or advise
us of the legal
   basis for ostensibly excluding the complete transaction histories of Mark E.
Watson III, Jay
   S. Bullock, Kathleen Nealon, and Gary V. Woods. In addition, please
reconcile how the
   following participants, as determined under Instruction 3 to Item 4 of
Schedule 14A,
   seemingly have been entirely omitted from the transaction history table:
Thomas A. Bradley,
   Jose Hernandez, Matthew Harris, Dymphna Lehane, Kevin Rehnberg, and Axel
Schmidt.


       We remind you that the registrant is responsible for the accuracy and
adequacy of its
disclosures, notwithstanding any review, comments, action or absence of action
by the staff.

        You may contact me at (202) 551-3266 with any questions.


                                                           Sincerely,

                                                           /s/ Nicholas P.
Panos

                                                           Nicholas P. Panos
                                                           Senior Special
Counsel
                                                           Office of Mergers &
Acquisitions

cc:     Adam M. Givertz, Esq.