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                           September 5, 2023

       Mark Kociancic
       Chief Financial Officer
       Everest Re Group, Ltd.
       Seon Place - 4th Floor
       141 Front Street
       PO Box HM 845
       Hamilton HM 19, Bermuda

                                                        Re: Everest Re Group,
Ltd.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2022
                                                            Filed February 24,
2023
                                                            File No. 001-15731

       Dear Mark Kociancic:

              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 ten 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 filed February 24, 2023

       General

   1.                                                   We note that you
provided more expansive disclosure in your 2021 Corporate Social
                                                        Responsibility Report
and 2022 Corporate Responsibility Report Supplemental
                                                        Disclosures (together,
the    CSR Reports   ) than you provided in your SEC filings. Please
                                                        advise us what
consideration you gave to providing the same type of climate-related
                                                        disclosure in your SEC
filings as you provided in your CSR Reports.
 Mark Kociancic
FirstName
Everest Re LastNameMark   Kociancic
           Group, Ltd.
Comapany 5,
September  NameEverest
              2023      Re Group, Ltd.
September
Page 2     5, 2023 Page 2
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Operation, page
41

2.       To the extent material, discuss the indirect consequences of
climate-related regulation or
         business trends, such as the following:

                decreased demand for products or services that produce
significant greenhouse gas
              emissions or are related to carbon-based energy sources;
                increased demand for products or services that result in lower
emissions than
              competing products;
                increased competition to develop innovative new products that
result in lower
              emissions;
                increased demand for generation and transmission of energy from
alternative energy
              sources; and
                any anticipated reputational risks resulting from operations or
products that produce
              material greenhouse gas emissions.
3.       We note disclosure in your Form 10-K that climate change may increase
the frequency
         and severity of natural catastrophes and the resulting losses in the
future and impact your
         risk modeling assumptions. We further note disclosure in your Proxy
Statement filed
         April 14, 2023, that insured losses due to extreme weather events are
increasing over time,
         and as climate change worsens, these losses will continue to grow.
Please discuss the
         physical effects of climate change on your operations and results.
This disclosure may
         include the following:

                severity of weather, such as floods, hurricanes, sea levels,
arability of farmland,
              extreme fires, and water availability and quality;
                quantification of material weather-related damages to your
property or operations;
                potential for indirect weather-related impacts that have
affected or may affect your
              major customers or insured locations; and
                any weather-related impacts on the cost or availability of
(re)insurance.

         Include quantitative information for each of the periods covered by
your Form 10-K and
         explain whether increased amounts are expected in future periods.
4.       Your CSR Reports reference a five-year purchase agreement for
certified carbon offsets
         and voluntary purchases of carbon offset credits. If material, provide
disclosure about
         your purchase or sale of carbon credits or offsets and any material
effects on your
         business, financial condition, and results of operations. Include
quantitative information
         for each of the periods covered by your Form 10-K and for future
periods in your
         response.
 Mark Kociancic
FirstName
Everest Re LastNameMark   Kociancic
           Group, Ltd.
Comapany 5,
September  NameEverest
              2023      Re Group, Ltd.
September
Page 3     5, 2023 Page 3
FirstName LastName
        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.

       Please contact Madeleine Mateo at 202-551-3465 or Jennifer Angelini at
202-551-3047
with any questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Finance