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United States securities and exchange commission logo





                             December 18, 2020

       Mark A. Wilcox
       Executive Vice President and Chief Financial Officer
       Selective Insurance Group, Inc.
       40 Wantage Avenue
       Branchville, New Jersey 07890

                                                        Re: Selective Insurance
Group, Inc.
                                                            Form 10-K for the
Fiscal Year Ended December 31, 2019
                                                            Filed February 12,
2020
                                                            Form 10-Q for the
Quarterly Period Ended September 30, 2020
                                                            Filed October 29,
2020
                                                            File No. 001-33067

       Dear Mr. Wilcox:

              We have reviewed your filings 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 10 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.

       Form 10-K for the Fiscal Year Ended December 31, 2019

       Notes to Consolidated Financial Statements
       Note 2: Summary of Significant Accounting Policies
       (n) Federal Income Tax, page 81

   1.                                                   In your policy note you
disclose that any interest levied by the Internal Revenue Service
                                                        would be recognized in
interest expense and any penalties would be recognized in either
                                                        other insurance
expenses or corporate expenses. In Note 13 on page 114 you disclose
                                                        that any such interest
and penalties will be included in income tax expense. Please
                                                        represent to us that in
future filings you will revise your disclosure to remove this
                                                        inconsistency.
 Mark A. Wilcox
Selective Insurance Group, Inc.
December 18, 2020
Page 2
Form 10-Q for the Quarterly Period Ended September 30, 2020

Notes to Unaudited Interim Consolidated Financial Statements
Note 1: Basis of Presentation and Accounting Policies
(b) Accounting Policies
Investments, page 6

2.       Although we note that you have adopted ASU 2016-13 and that you
revised your
         investment policy note to reflect your current expected credit losses
on investment
         securities, you continue to refer to other than-temporary impairments
("OTTI"). As both
         temporary impairments and OTTI were constructs of predecessor
requirements and the
         length of time a security's fair value is below amortized cost is no
longer a factor as to
         whether a charge to earnings for that security's impairment is
warranted, please represent
         to us that you will revise your policy and other investment
disclosures (including that on
         the face of your statements of income) to remove reference to OTTI for
periods after
         January 1, 2020.
Note 4: Investments, page 10

3.       In sub-note (f) on page 13 you disclose that you do not have exposure
to any credit
         concentration risk of a single issuer greater than 10% of your
stockholders' equity, other
         that certain U.S. government agencies. We note that on page 54 of your
September 30,
         2020 Form 10-Q you provided more granular information about the credit
quality of your
         investment portfolio compared to prior practice in your annual and
quarterly reports.
         Please tell us whether you have exposure to any significant industry
sector concentrations
         in your corporate securities and overall investment portfolios and
your consideration for
         disclosing the information required by ASC 825-10-50-21 in your
upcoming Form 10-K.
         In your response, specifically tell us your exposures to the
industries you identify as being
         negatively impacted by the COVID-19 pandemic in the first bullet of
your risk factor on
         page 56 of your September 30, 2020 Form 10-Q.
        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 Mark Brunhofer at (202) 551-3638 or Sharon Blume at (202)
551-
3474 with any questions.



FirstName LastNameMark A. Wilcox                               Sincerely,
Comapany NameSelective Insurance Group, Inc.
                                                               Division of
Corporation Finance
December 18, 2020 Page 2                                       Office of
Finance
FirstName LastName
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