VIA FEDERAL EXPRESS

August 16, 2018

Attention: Ms. Christine Westbrook and Ms. Erin Jaskot

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, D.C. 20549-0404

Re: Watford Holdings Ltd.

Amendment No. 6 to Draft Registration

Statement on Form S-1

Submitted July 31, 2018

Amendment No. 5 to Draft Registration

Statement on Form S-1

Submitted March 9, 2018

CIK No: 0001601669

Dear Ms. Westbrook and Ms. Jaskot:

On behalf of our client, Watford Holdings Ltd., a Bermuda exempted company with limited liability (the “Company”), we are confidentially submitting Amendment No. 7 to the Company’s draft Registration Statement on Form S-1 (as so amended, the “Registration Statement”) to the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”). The Company has revised the Registration Statement to update certain disclosures.

We have enclosed with this letter a marked copy of the Registration Statement, which was confidentially submitted today by the Company via EDGAR, reflecting all changes made since Amendment No. 5 to the Company’s draft Registration Statement on Form S-1, which the Company confidentially submitted on March 9, 2018 (“Amendment No. 5”). The Company has prepared the marked copy against Amendment No. 5 because Amendment No. 6 to the Company's draft Registration Statement on Form S-1, which the Company confidentially submitted on July 31, 2018 (“Amendment No. 6”), did not contain within it a copy of the prospectus. The Company further notes that all changes the Company previously proposed in its cover letter that accompanied Amendment No. 6 have now been reflected in the registration statement.

Should the Staff have additional questions or comments regarding any of the foregoing, please do not hesitate to contact the undersigned at (212) 878-3079 or Gary D. Boss at (212) 878-8063. Any written materials should be sent to the undersigned’s attention: Clifford Chance US LLP, 31 West 52^nd St., New York, NY 10019, Attention: Per B. Chilstrom, Esq.

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Ms. Westbrook Ms. Jaskot August 16, 2018 Page 2

Sincerely,

/s/ Per B. Chilstrom

Per B. Chilstrom

cc: Securities and Exchange Commission

Keira Nakada

Kevin Vaughn

Watford Holdings Ltd.

John F. Rathgeber

Clifford Chance US LLP

Gary D. Boss

Davis Polk & Wardwell LLP

Richard D. Truesdell, Jr.

Shane Tintle

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