March 24, 2020

Mark Harmsworth
Chief Financial Officer
HCI Group, Inc.
5300 West Cypress Street, Suite 100
Tampa, FL 33607

       Re: HCI Group, Inc.
           Form 10-K filed March 6, 2020
           File No. 001-34126

Dear Mr. Harmsworth:

       We have limited our review of your filing to the financial statements
and related
disclosures 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.

December 31, 2019 Form 10-K

Limited Partnership Interests, page 50

1.     We note your disclosure that you have no influence over partnership
operating and
       financial policies and that you use the equity method to account for
these investments.
       We also note your disclosure of your ownership percentages of certain
limited
       partnerships was between 0.18% and 2.24% on page 59. Please tell us the
accounting
       guidance that supports accounting for these investments using the equity
method. Please
       tell us specifically how you considered the guidance in ASC 323-30-S99
and ASC 970-
       323-25-6 which appears to indicate that the equity method is not
appropriate if an interest
       is so minor that you have virtually no influence over partnership
operating and financial
       policies.
c) Limited Partnership Investments, page 59

2.     We note your disclosure that you recognize your share of earnings or
losses based on the
       respective limited partnership's statement of income. We also note your
disclosure that
 Mark Harmsworth
HCI Group, Inc.
March 24, 2020
Page 2
         the limited partnerships had a net loss of $112 million during 2019
but that you
         recognized income of $1.2 million during 2019. Please tell us and
revise future filings to
         explain why you recognized income when the limited partnerships
recognized losses.
       In closing, 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.

      You may contact Michael Volley, Staff Accountant, at 202-551-3437 or Amit
Pande,
Accounting Branch Chief, at 202-551-3423 with any questions.



FirstName LastNameMark Harmsworth                             Sincerely,
Comapany NameHCI Group, Inc.
                                                              Division of
Corporation Finance
March 24, 2020 Page 2                                         Office of Finance
FirstName LastName