United States securities and exchange commission logo June 17, 2020 Reid Campbell Chief Financial Officer White Mountains Insurance Group Ltd. 80 South Main Street Hanover, New Hampshire 03755 Re: White Mountains Insurance Group Ltd. Form 10-K for the Fiscal Year Ended December 31, 2019 Filed March 2, 2020 File No. 001-08993 Dear Mr. Campbell: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Finance