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<SEC-DOCUMENT>0000000000-05-025580.txt : 20060526
<SEC-HEADER>0000000000-05-025580.hdr.sgml : 20060526
<ACCEPTANCE-DATETIME>20050524125824
<PRIVATE-TO-PUBLIC>
ACCESSION NUMBER:		0000000000-05-025580
CONFORMED SUBMISSION TYPE:	UPLOAD
PUBLIC DOCUMENT COUNT:		1
FILED AS OF DATE:		20050524

FILED FOR:		

	COMPANY DATA:	
		COMPANY CONFORMED NAME:			INVESTORS TITLE CO
		CENTRAL INDEX KEY:			0000720858
		STANDARD INDUSTRIAL CLASSIFICATION:	TITLE INSURANCE [6361]
		IRS NUMBER:				561110199
		STATE OF INCORPORATION:			NC
		FISCAL YEAR END:			1231

	FILING VALUES:
		FORM TYPE:		UPLOAD

	BUSINESS ADDRESS:	
		STREET 1:		121 N COLUMBIA ST
		STREET 2:		P O DRAWER 2687
		CITY:			CHAPEL HILL
		STATE:			NC
		ZIP:			27514
		BUSINESS PHONE:		9199682200

	MAIL ADDRESS:	
		STREET 1:		121 NORTH COLUMBIA STREET
		CITY:			CHAPEL HILL
		STATE:			NC
		ZIP:			27514
PUBLIC REFERENCE ACCESSION NUMBER:		0001169232-05-001699
</SEC-HEADER>
<DOCUMENT>
<TYPE>LETTER
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>







Via Facsimile and U.S. Mail
Mail Stop 03-09


May 24, 2005


Mr. James A. Fine, Jr.
Chief Financial Officer
Investors Title Company
121 North Columbia Street
Chapel Hill, NC 27514

Re:	Investors Title Company
	Form 10-K for the fiscal year ended December 31, 2004

	File No. 000-11774

Dear Mr. Fine:

      We have reviewed your filing and have the following comment.
We
have limited our review of the above referenced filing to only
those
issues addressed. In our comment, we ask you to provide us with
supplemental information so we may better understand your
disclosure.
Please provide us the supplemental information requested within 10
business days of the date of this letter or tell us when you will
provide a response prior to the expiration of the 10-day period.
Please furnish a letter with your supplemental responses that keys
your response to our comment.  Detailed letters greatly facilitate
our review.  You should file the letter on EDGAR under the form
type
label CORRESP.  Please understand that we may have additional
comments after reviewing your response to our comment.

	Please understand that the purpose of our review process is
to
assist you in your compliance with the applicable disclosure
requirements and to enhance the overall disclosure in your filing.
We look forward to working with you in these respects.  We welcome
any questions you may have about our comment or on any other
aspect
of our review.  Feel free to call us at the telephone numbers
listed
at the end of this letter.











Form 10-K for the fiscal year ended December 31, 2004

Management`s Discussion and Analysis of Financial Condition and
Results of Operations

Critical Accounting Policies

Reserves for Claims

1. We believe your disclosure in Management`s Discussion and
Analysis
regarding the reserve for claims could be improved to better
explain
the judgments and uncertainties surrounding this estimate and the
potential impact on your financial statements.  We believe that
disclosures explaining the likelihood that materially different
amounts would be reported under different conditions or using
different assumptions is consistent with the objective of
Management`s Discussion and Analysis.  Accordingly, please provide
us
information supporting this objective including the following
information as well as your analysis supporting why you excluded
this
information from the filing:

a. The range of loss reserve estimates as determined by your
actuaries.  Discuss the key assumptions used to arrive at
management`s best estimate of loss reserves within that range and
what specific factors led management to believe this amount rather
than any other amount within the range represented the best
estimate
of incurred losses. In addition include quantified and narrative
disclosure of the impact that reasonably likely changes in one or
more of the variables (i.e. actuarially method and/or assumptions
used) would have on reported results, financial position and
liquidity.

b. If you do not calculate a range around your loss reserve, but
instead use point estimates please tell us:

* The various methods considered and the method that was selected
to
calculate the reserves.  If multiple point estimates are
generated,
include the range of these point estimates.  Include a discussion
of
why the method selected was more appropriate over the other
methods.
* How management determined the most appropriate point estimate
and
why the other point estimates were not chosen.  Also clarify
whether
the company actually records to the point estimate or if not, how
that estimate is used.
* The quantified and narrative impact that reasonably likely
changes
in one or more of the variables (i.e. actuarially method and/or
assumptions used) would have on reported results, financial
position
and liquidity.

2. Based on your disclosure it is unclear whether you accrue your
policy reserve when the premiums are recognized as revenue.
Please
tell us management`s policy for recognizing claim reserves and how
your policy complies with paragraph 17 of SFAS 60.


*    *    *    *


	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require.
Since the company and its management are in possession of all
facts
relating to a company`s disclosure, they are responsible for the
accuracy and adequacy of the disclosures they have made.

	In connection with responding to our comments, please
provide,
in writing, a statement from the company acknowledging that

* the company is responsible for the adequacy and accuracy of the
disclosure in the filings;
* staff comments or changes to disclosure in response to staff
comments in the filings reviewed by the staff do not foreclose the
Commission from taking any action with respect to the filing; and
* the company may not assert staff comments as a defense in any
proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Corporation Finance in our review of your filing or in
response to our comments on your filing.

      You may contact Joseph Roesler, Staff Accountant, at (202)
551-
3628 or Joel Parker, Branch Chief, at (202) 551-3651 if you have
questions regarding the comments. In this regard, do not hesitate
to
contact me, at (202) 551-3679.

								Sincerely,


								Jim B. Rosenberg
								Senior Assistant Chief
Accountant
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James A. Fine, Jr.
Investors Title Company
Page 3






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