February 25, 2019

Mac Armstrong
Chief Executive Officer
GC Palomar Holdings
7979 Ivanhoe Avenue, Suite 500
La Jolla, CA 92037

       Re: GC Palomar Holdings
           Amendment No. 1 to Draft Registration Statement on Form S-1
           Submitted February 13, 2019
           CIK No. 0001761312

Dear Mr. Armstrong:

      We have reviewed your amended draft registration statement 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 this letter by providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. If you do not believe our comments apply to your facts and circumstances
or do not
believe an amendment is appropriate, please tell us why in your response.

       After reviewing the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
February 8, 2019 letter.

Amendment No. 1 to DRS on Form S-1

Prospectus Summary
Our Competitive Strengths, page 5

1.     We note your response to prior comment 1 and your revised disclosures
that effective
       January 1, 2019, you retain $5 million of risk per event. Your prior
disclosure had
       explained that such sum includes an amount retained through
co-participation in your
       reinsurance program. As you provide reinsurance through your reinsurance
subsidiary,
       please revise your disclosures to clarify whether the updated amount of
risk retained is
       inclusive or exclusive of any sums retained through your own reinsurance
operations.
 Mac Armstrong
GC Palomar Holdings
February 25, 2019
Page 2
Risk Factors
Our certificate of incorporation will provide that the Court of Chancery of the
State of Delaware
will be the exclusive forum. . ., page 39

2.     We note your revised disclosures in response to prior comment 6. Please
also revise to
       state that shareholders will not be deemed to have waived your
compliance with the
       federal securities laws and the rules and regulations thereunder.
Principal Stockholders, page 125

3.     We acknowledge your response and revised disclosures addressing prior
comment 4.
       Following the domestication, please revise the stockholder table to
reflect the
       ownership following the transaction. In addition, please disclose the
persons who have
       voting and investment control at Genstar Capital.
       You may contact Bonnie Baynes at 202-551-4924 or Lisa Vanjoske at
202-551-3614 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Dorrie Yale at 202-551-8776 or Mary Beth Breslin at 202-551-3625 with
any other
questions.



                                                            Sincerely,
FirstName LastNameMac Armstrong
                                                            Division of
Corporation Finance
Comapany NameGC Palomar Holdings
                                                            Office of
Healthcare & Insurance
February 25, 2019 Page 2
cc:       Michael S. Kagnoff, Esq.
FirstName LastName