[Scottish Re Group Limited Letterhead] September 26, 2007 BY EDGAR AND FEDERAL EXPRESS Jim B. Rosenberg Senior Assistant Chief Accountant Division of Corporation Finance United States Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549 Re: Scottish Re Group Limited Form 10-K for the Fiscal Year Ended December 31, 2006 Filed March 1, 2007 Amended Form 10-K for the Fiscal Year Ended December 31, 2006 Filed April 26, 2007 Form 10-Q for the Quarter Ended June 30, 2007 Filed August 14, 2007 File Number: 001-16855 Dear Mr. Rosenberg: We are writing in connection with the comments given by the staff of the Division of Corporation Finance of the United States Securities and Exchange Commission (the "Commission") set forth in your letter dated September 12, 2007 to Duncan Hayward, Chief Accounting Officer of Scottish Re Group Limited (the "Company"), with respect to the above-referenced Form 10-K for the fiscal year ended December 31, 2006, as amended, and the Form 10-Q for the quarter ended June 30, 2007. The Company continues to consider the comments raised, and requests an extension in order to complete its responses. The Company intends to respond to the Commission's comments no later than October 10, 2007. If you have further questions, please contact me at +44 (0)20 7709 1910. Sincerely, /s/ Duncan Hayward Duncan Hayward Mr. Jim B. Rosenberg September 26, 2007 Page 2 Sasha Parikh Securities and Exchange Commission James Atkinson Securities and Exchange Commission George Zippel Scottish Re Group Limited Paul Goldean Scottish Re Group Limited Charles Anderson Scottish Re Group Limited Amy Baker Ernst & Young LLP Andy Betts Ernst & Young LLP Stephen G. Rooney LeBoeuf, Lamb, Greene & MacRae LLP