Via Facsimile and U.S. Mail
Mail Stop 6010


October 27, 2005


Mr. Andrew Cook
Chief Financial Officer,
Axis Capital Holdings Limited
106 Pitts Bay Road
Pembroke, Bermuda HM 08

Re:	Axis Capital Holdings Limited
	Form 10-K for Fiscal Year Ended December 31, 2004
	Filed on March 1, 2005

	File No. 001-31721

Dear Mr. Cook:

      We have limited our review of your filing to those issues we
have addressed in our comments. In our comments, we ask you to
provide us with information so we may better understand your
disclosure.  After reviewing this information, we may raise
additional comments.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.

Form 10-K for Year Ended December 31, 2004

Item 7. Management`s Discussion and Analysis of Financial
Condition
and Results of Operations

Critical Accounting Policies

Reserve for losses and loss expenses, page 45

1. It appears based on your disclosure that you do not calculate a
range around your loss reserve, but instead use point estimates.
Please provide us in a disclosure type format the following:


* Disclose the various methods considered and the method that was
selected to calculate the reserves.  If multiple point estimates
are
generated, include the range of these point estimates.  Include a
discussion of why the method selected was more appropriate over
the
other methods.
* Discuss how management determined the most appropriate point
estimate and why the other point estimates were not chosen.  Also
clarify whether the company actually records to the point estimate
or
if not, how that estimate is used.
* Include quantified and narrative disclosure of the impact that
reasonably likely changes in one or more of the variables (i.e.
actuarially method and/or assumptions used) would have on reported
results, financial position and liquidity.

2. We note that you set your claim reserves for assumed
reinsurance
operations based upon information received from the cedant.  As
this
appears to pose a potential for a higher degree of uncertainty in
establishing the estimate of assumed loss reserves as compared to
direct loss reserves, please provide us in a disclosure type
format
your disclosure related to this uncertainty.  Also in this
disclosure, please consider disclosing the following:

a. Include in this disclosure the risks associated with making
this
estimate and the effects and expected effects this uncertainty has
or
will have on management`s judgments and assumptions in
establishing
the assumed loss reserve.
b. The nature and extent of the information received from the
cedants
related to policies, claims, unearned premiums and loss reserves;
c. The time lag from when claims are reported to the cedant to
when
the cedant reports them to the company and whether, how, and to
what
extent this time lag effects the loss reserve estimate;
d. How management uses the information received from the cedants
in
its determination of its assumed loss reserves, whether
reinsurance
intermediaries are used to transact and service reinsurance
policies,
and how that impacts the loss reserving methodology;
e. The amount of any backlog related to the processing of assumed
reinsurance information, whether the backlog has been reserved for
in
the financial statements and, if applicable, when the backlog will
be
resolved;
f. What process management performs to determine the accuracy and
completeness of the information received from the cedants;
g. How management resolves disputes with cedants, how often
disputes
occur, and the magnitude of any current, material disputes; and
h. Whether management uses historical loss information to validate
its existing reserves and/or as a means of noticing unusual trends
in
the information received from the cedants.







Consolidated Financial Statements

Notes to Consolidated Financial Statements

2. Summary of Significant Accounting Policies

i) Derivative Contracts, page 100
3. Please tell us the nature of the insurance products
underwritten
that you account for as derivatives.  Please also tell us how you
account for and classify premiums and losses resulting from these
insurance products.


*    *    *    *


      Please respond to the comments within 10 business days or
tell
us when you will provide us with a response.  Please furnish a
letter
that keys your responses to our comments and provides requested
information.  Detailed letters greatly facilitate our review.
Please
file your letter on EDGAR under the form type label CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings to be certain that the
filing includes all information required under the Securities and
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  Since the
company and its management are in possession of all facts relating
to
a company`s disclosure, they are responsible for the accuracy and
adequacy of the disclosures they have made.

	In connection with responding to our comment, please provide,
in
writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments do not foreclose the Commission from taking any action
with
respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

	In addition, please be advised that the Division of
Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.




      You may contact Joseph Roesler, Staff Accountant, at (202)
551-
3628 or Joel Parker, Accounting Branch Chief, at (202) 551-3651 if
you have questions regarding the comments. In this regard, do not
hesitate to contact me, at (202) 551-3679.

								Sincerely,


								Jim B. Rosenberg
								Senior Assistant Chief
Accountant
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Mr. Andrew Cook
Axis Capital Holdings Limited
October 27, 2005
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