November 21, 2008

 

Via Edgar

 

Jim B. Rosenberg

Senior Assistant Chief Accountant

Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549-1090

 

Re:	Financial Security Assurance Holdings Ltd.
	Form 10-K for the Fiscal Year Ended December 31, 2007
	Filed March 20, 2008
	Form 10-Q for the Quarterly Period Ended March 31, 2008
	Filed May 15, 2008
	File Number: 001-12644

 

Dear Mr. Rosenberg:

 

On November 12, 2008, Financial Security Assurance Holdings Ltd. (the “Company”) received a letter with comments from the Staff of the Securities and Exchange Commission on the Company’s annual report on Form 10-K for the year ended December 31, 2007, filed on March 20, 2008, and the Company’s quarterly report on Form 10-Q for the quarter ended June 30, 2008, filed on August 14, 2008.

 

In its letter, the Staff requested that the Company either provide its response within 10 business days or advise the Staff when it would respond.  I hereby respectfully request that the Staff provide the Company an additional ten business days to respond to the November 12, 2008 letter, until Thursday, December 11, 2008.  As previously reported, on November 14, 2008, the Company’s parent, Dexia S.A. (“Dexia”), announced that Dexia and Assured Guaranty Ltd. (“Assured Guaranty”) have entered into a purchase agreement for Assured Guaranty to acquire all of Dexia’s shares of the Company, subject to the completion of specified closing conditions.   Due to the demands on the Company’s accounting and legal staff in connection with the due diligence related to this transaction we would appreciate additional time to respond to the November 12, 2008 letter.

 

Please direct any comments or questions you may have regarding this request to me at (212) 339-3483 or via e-mail at JSimon@FSA.com.

 

	Respectfully submitted,
	/s/ Joseph W. Simon
	Joseph W. Simon
	Chief Financial Officer and Managing Director