November 1, 2013
Via Edgar and Facsimile
Mr. Jeffrey P. Riedler, Assistant Director
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549-7010
| Re: | Blue Capital Reinsurance Holdings Ltd. Registration Statement on Form S-1 (SEC File No. 333-191586) |
Dear Mr. Riedler:
In accordance with Rule 461 under the Securities Act of 1933, as amended (the “Act”), Deutsche Bank Securities Inc., Barclays Capital Inc. and UBS Securities LLC, as representatives of the several underwriters (the “Representatives”), hereby join in the request of Blue Capital Reinsurance Holdings Ltd. (the “Company”) for acceleration of the above-referenced Registration Statement, as amended, requesting that such Registration Statement become effective on November 5, 2013, at 4:00 p.m. Eastern Time, or as soon thereafter as is practicable.
In connection with this acceleration request and pursuant to Rule 460 under the Act, please be advised that we have distributed approximately 3,160 copies of the Company’s Preliminary Prospectus, dated October 29, 2013 through the date hereof, to underwriters, dealers, institutions and others.
The Representatives confirm on behalf of themselves and the several underwriters that they have complied with the requirements of Rule 15c2-8 under the Securities Exchange Act of 1934, as amended.
[SIGNATURE PAGE FOLLOWS]
Very truly yours,
dEUTSCHE bANK SECURITIES
INC.
BARCLAYS CAPITAL INC.
UBS SECURITIES LLC
By: dEUTSCHE bANK SECURITIES INC.
| By | /s/ Neil Abromavage | |
| Name: Neil Abromavage | ||
| Title: Managing Director | ||
| By | /s/ Francis M. Windels | |
| Name: Francis M. Windels | ||
| Title: Managing Director | ||
By: BARCLAYS CAPITAL INC.
| By | /s/ Victoria Hale | |
| Name: Victoria Hale | ||
| Title: Vice President | ||
By: UBS SECURITIES LLC
| By | /s/ Michael Jamin | |
| Name: Michael Jamin | ||
| Title: Managing Director | ||
| By | /s/ Tushar Virmani | |
| Name: Tushar Virmani | ||
| Title: Director | ||
For themselves and as Representatives of the
other Underwriters named in Schedule I of the
Underwriting Agreement.
[Blue Capital Reinsurance Holdings Ltd. (File No. 333-191586) – Underwriters’ Acceleration Request]