November 15, 2019

Kirk Lusk
Chief Financial Officer
Heritage Insurance Holdings, Inc.
2600 McCormick Drive, Suite 300
Clearwater, Florida 33759

       Re: Heritage Insurance Holdings, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed March 12, 2019
           File No. 001-36462

Dear Mr. Lusk:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within 10 business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Critical Accounting Policies and Estimates
Reserves for Unpaid Losses and Loss Adjustment Expenses, page 52

1.    Please tell us why you removed your disclosure about the range of
actuarial estimates
      related to your latest loss reserve estimate. In this regard, we note you
previously provided
      this disclosure consistent with your April 2, 2014 response to comments
12 and 13 of our
      March 12, 2014 comment letter on your initial public offering draft
registration statement.
      In your response, tell us how your current disclosure provides readers
with information to
      assess the variability and sensitivity of your loss reserve estimate at
December 31, 2018 to
      reasonably likely changes in the key underlying reserving assumptions
consistent with the
      guidance in Section V of Release No. 33-8350.
Notes to Consolidated Financial Statements
Note 1: Basis of Presentation, Nature of Business and Significant Accounting
Policies and
 Kirk Lusk
Heritage Insurance Holdings, Inc.
November 15, 2019
Page 2
Practices
Policy Acquisition Costs, page 70

2.       You disclose that you defer certain expenses related to policy
issuance and underwriting
         that vary with and are directly related to the production of new
business. This language
         appears to be reasonably consistent with the definition of acquisition
costs prior to the
         adoption of ASU 2010-26. Please confirm that your policy defers only
those incremental
         direct costs that are directly related to the successful acquisition
of new or renewal
         insurance contracts consistent with the guidance in ASC 944-30-25-1A.
If so, represent to
         us that you will revise your policy disclosure in future filings to be
consistent with the
         current guidance. If not, tell us the impact of applying the guidance
in ASU 2010-26 on
         your deferred acquisition costs at December 31, 2016, 2017 and 2018
and at
         September 30, 2019.
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

        You may contact Bonnie Baynes at (202) 551-4924 or Mark Brunhofer at
(202) 551-
3638 if you have any questions.



FirstName LastNameKirk Lusk                                  Sincerely,
Comapany NameHeritage Insurance Holdings, Inc.
                                                             Division of
Corporation Finance
November 15, 2019 Page 2                                     Office of Finance
FirstName LastName