July 20, 2017

VIA EDGAR CORRESPONDENCE

Ms. Cecilia Blye

Chief, Office of Global Security Risk

Division of Corporation Finance

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549

Re: XL Group Ltd

Form 10-K for the Fiscal Year Ended December 31, 2016

Filed February 23, 2017

File No. 1-10804

Dear Ms. Blye:

We are in receipt of the letter dated July 7, 2017 from the staff (the “Staff”) of the U.S. Securities and Exchange Commission with respect to XL Group Ltd’s (“XL” or “we”) Annual Report on Form 10-K for the fiscal year ended December 31, 2016.

The letter requests XL to respond to the Staff’s comments within ten business days or to advise you when XL will provide its response.  XL has reviewed the Staff’s comments and has begun preparation of its response.  However, XL will require additional time to consider and respond fully to the Staff’s comments.  Accordingly, XL respectfully requests an extension of time to respond to the Staff’s comments until August 4, 2017.  We will endeavor to submit the response earlier if feasible.

Please call me at +1 (441) 292 8515 if you have questions regarding this letter. Thank you.

Very truly yours,

By: /s/ Kirstin Gould

General Counsel and Secretary

XL Group Ltd

cc:    Suzanne Hayes

Assistant Director

Division of Corporation Finance

Pradip Bhaumik

Special Counsel

Division of Corporation Finance

Satish M. Kini

Debevoise & Plimpton LLP