PO Box 407193 n Fort Lauderdale, Florida 33340 (954) 581-9993 office n (954) 316-9201 fax
	Via EDGAR - CORRESP

September 6, 2007

Mr. Jim B. Rosenberg

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Mail Stop 3-10

Washington D.C. 20549

RE: 21^st Century Holding Company

Form 10-K for the Fiscal Year Ended December 31, 2006

Filed March 16, 2007

File No. 0-25001

Dear Mr. Rosenberg:

In reference to our conversation with Mary Mast on August 27, 2007, pertaining to the above-referenced filing, please see the corresponding response following each item below.

1.   Please confirm that 21^st Century Holding Company will provide the proposed disclosures in comments 1, 2, 3, & 4 of the prior response letter dated August 9, 2007 to the SEC and additional disclosures requested below in the next periodic report filed by 21^st Century Holding Company.

We confirm that 21^st Century Holding Company will provide the proposed disclosures in comments 1, 2, 3, & 4 of our prior response letter dated August 9, 2007 to the SEC and additional disclosures requested below in the next periodic report filed by 21^st Century Holding Company.

2.   Under 2(b) of the Critical Accounting Policies response - Please clarify the methodology for recording short tail reserves and how that methodology differs from the long tail methodologies. In addition, please clarify how different methodologies are used for different lines of business.

The methods we use for our short-tail business do not differ from the methods we use for our long-tail business. The Incurred and Paid Development Methods, the Claims & Severity Method, and the Reserve Development Method intrinsically recognize the unique development characteristics contained within the historical experience of each material short-tail and long-tail line of business. The Incurred and Paid Bornhuetter-Fergusson Methods reflect similar historical development unique to each material short-tail and long-tail line of business.

Additionally, the different methodologies are utilized the same, regardless of the line of business. However, the final selection of ultimate loss and LAE is certain to vary by both line of business and by accident period maturity. There is no prescribed combination of line of business, accident year maturity, and methodologies; consistency in results of the different methodologies and reasonableness of the result are the primary factors that drive the final selection of ultimate loss and LAE.

3.   Under 2(f) of the Critical Accounting Policies response - Please clarify that management believes that the scenarios quantified are reasonably likely changes.

Edward Lawson, our Chief Executive Officer, and Pete Prygelski, our Chief Financial Officer, confirm that the changes in loss and loss adjustment reserves, net of reinsurance each represent reasonably likely changes, as previously noted in our response dated August 9, 2007.

4.   The unrealized losses in the schedule provided did not agree to the unrealized losses in Note 3 to the financial statements. In addition, please provide the aging schedule for unrealized losses for each statement of financial statement position presented in the financial statement.

The unrealized losses in the following schedules now agree with the unrealized losses in Note 3 to the financial statements. Please excuse the inclusion of the unrealized gains in our original response. The comparative tables are as follows:

December 31, 2006	Unrealized holdings net losses		Less than 12 months		12 months or longer
Fixed Maturities - Available For Sale:
U.S. government and agency obligations	$	713,464		148,500		650,964
Obligations of states and political
subdivisions		163,071		46,218		116,853
Corporate securities		92,773		-		92,773
	$	969,308	$	194,718	$	860,590
Fixed Maturities - Held To Maturity:
U.S. government and agency obligations	$	429,062		-		429,062
Obligations of states and political
subdivisions		7,023		-		7,023
Corporate securities		11,210		-		11,210
	$	447,295	$	-	$	447,295
Equity securities - common stocks	$	745,592	$	-	$	745,593

December 31, 2005		Unrealized holdings net losses		Less than 12 months		12 months or longer
Fixed Maturities - Available For Sale:
U.S. government and agency obligations	$	641,493		142,974		498,518
Obligations of states and political
subdivisions		157,160		27,225		129,935
Corporate securities		245,450		3,029		242,421
	$	1,044,103	$	173,228	$	870,874
Fixed Maturities - Held To Maturity:
U.S. government and agency obligations	$	404,194		60,230		343,963
Obligations of states and political
subdivisions		8,081		8,081		-
Corporate securities		12,810		-		12,810
	$	425,085	$	68,311	$	356,773
Equity securities - common stocks	$	1,479,994	$	806,489	$	915,044

If you should have any questions concerning the responses contained herein or require additional information, please feel free to contact me at (954) 308-1252.

Sincerely,

/s/ Peter J. Prygelski

Peter J. Prygelski, III

Chief Financial Officer