1 FINANCIAL PACIFIC INSURANCE GROUP, INC. 3850 Atherton Road Rocklin, California 95765 (916) 630-5000 July 23, 1998 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, D.C. 20549 Re: Financial Pacific Insurance Group, Inc. -- Registration Statement on Form 8-A (File No. 0-24349) ----------------------------------------------------- Ladies and Gentlemen: On April 20, 1998, Financial Pacific Insurance Group, Inc. (the "Company") filed a Registration Statement on Form S-1 (the "Form S-1," Registration No. 333-50511) with your office. On May 28, 1998, the Company filed the above-captioned Registration Statement on Form 8-A. Pursuant to Section 12(g)(1) of the Securities Exchange Act of 1934, as amended, the Form 8-A becomes effective 60 days after filing. As we do not anticipate that the Company's Form S-1 will be declared effective by July 27, 1998, we request the withdrawal of the Form 8-A at this time. The Company will refile a new Registration Statement on Form 8-A on a subsequent date. Thank you in advance for your assistance. Very truly yours, /s/ Robert C. Goodell Robert C. Goodell President and Chief Executive Officer cc: Mr. Joseph K. Pascale