[Willkie Farr & Gallagher LLP Letterhead]


May 5, 2009



VIA EDGAR

Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
Division of Corporation Finance
Securities and Exchange Commission
Mail Stop 6010
100 F Street, NE
Washington, D.C. 20549

Re:     RenaissanceRe Holdings Ltd.
        Form 10-K for Fiscal Year Ended December 31, 2008
        Filed February 20, 2009
        File No. 001-14428

Dear Mr. Rosenberg:

     On behalf of RenaissanceRe  Holdings Ltd. (the  "Company"),  we submit this
letter in response to comments  from the staff of the  Securities  and  Exchange
Commission  received  by letter  dated  April 23,  2009 (the  "Comment  Letter")
relating to the above-referenced filing. We are working expeditiously to respond
to the Comment Letter.  We respectfully  request an extension of time to respond
to the  inquiries  contained  in the Comment  Letter.  We  currently  anticipate
submitting a response to the Comment Letter on or before May 18, 2009. Please do
not  hesitate  to  contact me at  212-728-8736  with any  concerns  you may have
regarding the timetable described above. Thank you for your consideration.


Very truly yours,

/s/ Robert B. Stebbins

Robert B. Stebbins





cc:     Dana Hartz
        Donald Abbott
        Fred R. Donner
        Mark A. Wilcox
        Stephen H. Weinstein, Esq.