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United States securities and exchange commission logo





                            December 14, 2023

       Jeff Radke
       Chief Executive Officer
       Accelerant Holdings
       c/o Accelerant Re (Cayman) Ltd.
       Unit 106, Windward 3, Regatta Office Park
       West Bay Road, Grand Cayman

                                                        Re: Accelerant Holdings
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Submitted November
29, 2023
                                                            CIK No. 0001997350

       Dear Jeff Radke:

            We have reviewed your amended registration statement and have the
following
       comments.

              Please respond to this letter by amending your registration
statement and providing the
       requested information. If you do not believe a comment applies to your
facts and circumstances
       or do not believe an amendment is appropriate, please tell us why in
your response.

              After reviewing any amendment to your registration statement and
the information you
       provide in response to this letter, we may have additional comments.
Unless we note otherwise,
       any references to prior comments are to comments in our November 16,
2023 letter.

       Amendment No.1 to Draft Registration Statement on Form S-1 filed
November 29, 2023

       Summary Accelerant Holdings Historical Consolidated Financial Data, page
18

   1.                                                   We note your response
to prior comment 11 and revised disclosures. Your measures for
                                                        "organic revenue" and
the related "organic revenue growth rate    appear to represent non-
                                                        GAAP financial
measures. Please revise to label these as non-GAAP financial measures
                                                        and provide the
required disclosures.
       We rely on third parties to perform key functions of our business
operations , page 34

   2.                                                   We note your response
to prior comment 25. Please supplementally advise us how you
                                                        determined VantagePoint
and Soteria are not key third-party vendors on which your
                                                        business is dependent.
 Jeff Radke
Accelerant Holdings
December 14, 2023
Page 2
Technology and development operating expenses, page 81

3.       We note your response to prior comment 19 that management expects the
annual
         expenditure on the development of the Risk Exchange Technology as a
percentage of
         Exchange Written Premium to increase over the medium term. We also
note your
         disclosure on page 81 that you expect that your technology and
development costs will
         continue at a similar level for at least several years as you continue
to dedicate substantial
         investment to the development of your Risk Exchange. Please revise
your disclosure to
         reconcile these two statements. Make appropriate updates to your
disclosure related to
         key factors impacting your performance, where technology development
is described as a
         key factor.
Segment Information , page 94

4.       We note your response to prior comment 32. We also note your
disclosure in footnote 2 to
         the revenue table on page 95 and the revenue table on page F-77 that
ceding commissions
         income (adjustments) includes the effect of sliding scale adjustments.
Please revise here,
         and elsewhere in the document where sliding scale adjustments are
discussed, to quantify
         the sliding scale adjustments for the nine months ended September 30,
2023 and 2022, as
         applicable.
Investment Portfolio, page 108

5.       We note your response to prior comment 1, and your disclosure related
to equity price
         risks on page 120. Revise your disclosure, either in this section, or
elsewhere, to disclose
         any concentrations of investments in the equity securities in your
portfolio, including both
         sectors, industries, or individual companies.
6.       We note your response to prior comment 1, bullet point 4. Please
disclose the material
         terms of the investment management agreements, including the
identities of the parties to
         the agreements, the compensation structure with the investment
managers, any minimum
         amount of assets required to be covered under the agreement, and term
and termination
         provisions.
Member Case Studies, page 132

7.     We note your response to prior comment 28. Please disclose whether the
performance of
       these two examples is representative of new members who joined during
the same time
       periods. For example, you state that within two years of joining the
platform, Member B
FirstName LastNameJeff Radke
       nearly doubled its annual premiums and considerably reduced its loss
ratio. Your
Comapany    NameAccelerant
       disclosure should makeHoldings
                               clear whether Member B's performance is
representative of new
       members
December         whoPage
           14, 2023   joined
                          2 during the same time period.
FirstName LastName
 Jeff Radke
FirstName
Accelerant LastNameJeff  Radke
           Holdings
Comapany14,
December   NameAccelerant
               2023        Holdings
December
Page  3    14, 2023 Page 3
FirstName LastName
       Please contact William Schroeder at 202-551-3294 or Robert Klein at
202-551-3847 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Christian Windsor at
202-551-3419 with any
other questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Finance
cc:      Robert A. Ryan, Esq.
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