Via Facsimile and U.S. Mail
Mail Stop 6010


									December 22, 2005


Max Crisp
Executive Vice President and
Chief Financial Officer
Stewart Information Services Corporation
1980 Post Oak Boulevard
Houston, Texas 77056


Re:  	Stewart Information Services Corporation
      Form 10-K for the Fiscal Year Ended December 31, 2004
      Filed March 15, 2005
      File Number:  001-02658


Dear Mr. Crisp:

      We have reviewed your filing and have the following
comments.
We have limited our review of your filing to the issues we have
addressed in our comments.  In our comments, we ask you to provide
us
with additional information so we may better understand your
disclosures.  After reviewing this information, we may raise
additional comments.

	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 comments 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, page 8

Critical accounting estimates, page 8

Title loss reserves, page 8

1. Please provide to us in disclosure-type format the following:
* Because IBNR reserve estimates are more imprecise, please
disclose
the amount of IBNR separately from case reserves.
* Include a discussion of why management determined that the
percentage used to determine title losses was appropriate.
* Clarify whether the 0.1% change discussed is what management
would
expect as a reasonably likely scenario.  If this is not the
reasonably likely outcome, then revise the disclosure to include
what
a reasonably likely outcome would be.

Policy-issuing agency revenues, page 8

2. Please provide to us in disclosure-type format a discussion
that
quantifies the potential impact of the estimate on your financial
position.  Such information would potentially include but not be
limited to the amount of the accrual for all periods, the
adjustments
made to this estimate in the past, and some sensitivity analysis
related to this accrual.

Contractual obligations, page 11

3. Please provide to us in disclosure-type format a more detailed
discussion of why management is unable to determine the expected
payout of this reserve.  Include a discussion of why this
inability
to predict the payment period of its reserves will not materially
impact the ability to manage this business.  Further, explain to
us
supplementally why you are unable to make these determinations
when
we note that other companies within your industry are able to
estimate the period of payment.

* * * *

	Please provide us the additional information requested within
10
business days or tell us when you will provide us with a response.
Please furnish a cover letter with your response that keys your
response to our comments  Detailed cover letters greatly
facilitate
our review.  Please file your letter on EDGAR under the form type
label CORRESP.

	We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filing to be certain that the
filing includes all information required under the Securities
Exchange Act of 1934 and that they have provided all information
investors require for an informed investment decision.  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 your letter, a statement from the company acknowledging that:

* the company is responsible for the adequacy and accuracy of the
disclosure in the filing;
* 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
* 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 Vanessa Robertson, Staff Accountant, at
(202)
551-3649 or Jim Atkinson, Accounting Branch Chief, at (202) 551-
3674
if you have any 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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Max Crisp
Stewart Information Services Corporation
December 22, 2005
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