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                             December 17, 2021

       Scott Kirk
       Chief Financial Officer
       Argo Group International Holdings, Ltd.
       90 Pitts Bay Road
       Pembroke HM 08
       Bermuda

                                                        Re: Argo Group
International Holdings, Ltd.
                                                            Form 10-K for
Fiscal Year Ended December 31, 2020
                                                            Filed March 15,
2021
                                                            File No. 001-15259

       Dear Mr. Kirk:

               We have limited our review of your filing to the financial
statements and related
       disclosures and have the following comment. In our comment, we may ask
you to provide us
       with information so we may better understand your disclosure.

              Please respond to this comment within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comment applies to your facts and circumstances, please tell us why in
your response.

                                                        After reviewing your
response to this comment, we may have additional comments.

       Form 10-K filed March 15, 2021

       Note 2. Revisions of Previously Issued Financial Statements, page F-17

   1.                                                   We note your disclosure
that you identified certain immaterial errors in your historical
                                                        financial statements
primarily related to the accounting for (1) foreign currency exchange
                                                        gains and losses
associated with a specific reinsurance contract and (2) errors in the
                                                        Company   s tax
provision primarily related to the Company   s allocation of certain
                                                        corporate-level
expenses to your subsidiary companies, as well as other previously
                                                        identified immaterial
errors. We further note your disclosure that you concluded that
                                                        although these errors
were not material to the previously issued financial statements,
                                                        however, correcting the
cumulative effect of the errors in 2020 would materially misstate
                                                        the 2020 consolidated
financial statements, and therefore you have revised your historical
                                                        financial statements to
correct for these immaterial errors. In light of the nature of the
                                                        errors and their
quantitative significance to the adjusted financial statements presented,
 Scott Kirk
Argo Group International Holdings, Ltd.
December 17, 2021
Page 2
         including, for instance income tax provision, net income (loss) and
earnings per share for
         certain of the revised periods, please provide us with your analysis
considering the
         guidance in Staff Accounting Bulletin No. 99. In your response please
discuss how you
         evaluated the total mix of information, taking into account both
quantitative and
         qualitative factors considered, when determining materiality of the
error to investors and
         other users.
       In closing, 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 William Schroeder at 202-551-3294 or John Spitz at
202-551-3484 with
any questions.



FirstName LastNameScott Kirk                         Sincerely,
Comapany NameArgo Group International Holdings, Ltd.
                                                     Division of Corporation
Finance
December 17, 2021 Page 2                             Office of Finance
FirstName LastName