[Ohio Casualty Corporation letterhead]

Michael A. Winner, CPA
Executive Vice President & Chief Financial Officer




February 28, 2006



Mr. Jim B. Rosenberg
Senior Assistant Chief Accountant
Division of Corporation Finance
Securities and Exchange Commission
100 F Street, N.E.
Mail Stop 6010
Washington  DC  20549


Re:  Ohio Casualty Corporation
     Form 10-K for Fiscal Year Ended December 31, 2004
     File No. 0-05544


Dear Mr. Rosenberg:


Ohio Casualty Corporation ("Corporation") acknowledges it has received the
written comments from the staff of the Securities and Exchange Commission
(the "Staff" or "Commission") in a letter dated February 22, 2006, in
response to its letter to the Commission dated February 13, 2006.  For ease
of reference, we have restated the Staff's comments within our responses.

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

Management's Discussion and Analysis, page 18

Loss and Loss Adjustment Expenses, page 39
- ------------------------------------------

  1. Comment:  Please explain to us why you removed the disclosure
     regarding how management adjusts the point estimates determined by your
     actuaries in establishing your loss reserves in response to our previous
     comment two.  As previously requested, please revise your proposed
     disclosure to indicate the point estimate made by your actuaries for each
     product line and what specific factors/justifications you used to adjust
     the point estimates.

     Response:  The Corporation revised its prior disclosure in this area,
     as referenced by the Staff, as a result of the Corporation's
     reevaluation of this disclosure in light




9450 Seward Road, Fairfield, OH 45014      Telephone: 513-603-2267
Fax: 513-603-3134      mike.winner@ocas.com






     of the Staff's previous comments.  Under the prior disclosure, the
     Staff could infer, that when the Corporation states it records its best
     estimate of loss reserves by "considering" the actuaries' estimates, it
     could mean some adjustment is made by management to the actuaries'
     estimates, when in fact that does not occur. Further, under the previous
     disclosure the Staff could infer that the Corporation has a bifurcated
     reserving process involving both our actuaries and then management.
     However, there is no bifurcated process.  Our actuaries, who are part of
     management, are responsible for the Corporation's loss reserve
     analysis. The Corporation uses the results from this loss reserve
     analysis to record its loss reserve estimates in its financial
     statements.   The revision you referenced is intended to clarify our
     process for the Staff.

     As a result, we believe there is no revision to our disclosure
     required, since the estimates made by our actuaries by product line
     are the amounts reflected in our financial statements.

  2. Comment:  We note your proposed revised disclosure provided in
     response to our previous comment three regarding your loss sensitivity
     analysis and acknowledge that your reserving process is complex.  However,
     we continue to believe that significant assumptions exist in the reserving
     process for every product line.  Significant assumptions are those
     assumptions that could involve the greatest amount of judgment or those
     assumptions that have the greatest financial impact on the loss reserve.
     Please revise your proposed disclosure to quantify the impact of reasonably
     likely changes in your significant assumptions on your loss reserves for
     each product line.

     Response:  The Corporation understands that some companies may make
     significant explicit assumptions to determine reserve estimates.
     However, as we indicated in our response letter dated January 17, 2006
     and in our telephone call with the Staff on February 13, 2006, the
     Corporation does not make explicit assumptions, significant or not, in
     determining its reserve estimates.  As described in our proposed
     disclosure of Annual Report of Form 10-K for the year ending December
     31, 2005 as previously provided, the Corporation principally utilizes
     five reserving methods to establish loss reserves. We rely on the
     first two methods most often and utilize methods three, four and five,
     and other methods, when appropriate. Of these five methods, the first
     four rely on historical loss data; trends, risk factors and other
     information are incorporated into the loss estimates only to the
     extent they are reflected implicitly in the data. The fifth method
     does utilize loss severity trend assumptions; however, when this
     method is used, it is only in conjunction with the first four methods
     to select reserve estimates.  Reserve estimates are made based upon
     the particular combination of methods deemed most appropriate. And we
     do not determine reasonably likely alternative scenarios.  The loss
     reserve process takes all risk factors, as previously disclosed, into
     account, but no one risk factor can be bifurcated to perform
     sensitivity analysis because the risk factors are considered in the
     aggregate.  As a result, we are not in a position to quantify the
     impact of reasonably likely changes to explicit




     assumptions nor revise our proposed disclosure since no such scenarios
     or quantification exist.


In response to your previous request to include the following, please be
advised the Corporation reconfirms and acknowledges:
  - that it is responsible for the adequacy and accuracy of the disclosure
    in the filing;
  - that staff comments or changes to disclosure in response to staff
    comments do not foreclose the Commission from taking any action with
    respect to the filing; and that the Corporation 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.


You may contact Debra K. Crane, Senior Vice President, General Counsel and
Secretary, by telephone at (513) 603-2213 or via fax at (513) 603-2208 or
email at Debra.Crane@ocas.com if you have questions or comments on the
responses of the Corporation.


Sincerely,




/s/Michael A. Winner

Michael A. Winner
Executive Vice President and
Chief Financial Officer