July 12, 2019

Guy Bowker
Chief Financial Officer
Enstar Group LTD
Windsor Place, 3rd Floor
22 Queen Street
Hamilton HM JX, Bermuda

       Re: Enstar Group Limited
           Form 10-K for the fiscal year ended December 31, 2018
           Filed March 1, 2019
           File No. 001-33289

Dear Mr. Bowker:

        We have reviewed your June 13, 2019 response to our comment letter 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 the 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 the comment, we may have additional
comments.
Unless we note otherwise, our references to prior comments are to the comment
in our May 15,
2019 letter.

Form 10-K for fiscal year ended December 31, 2018

Notes to Consolidated Financial Statements
10. Losses and Loss Adjustment Expenses
Loss Development Information
Disclosures of Incurred and Paid Loss Development, IBNR, Claims Counts and
Payout
Percentages, page 182

1.     We acknowledge the information provided in your response to our prior
comment 1 and
       believe that additional disclosure explaining the methodologies used to
prepare the
       incurred loss and cumulative paid loss tables would be beneficial.
Please provide us with
       proposed revised disclosure to be included in your 2019 Form 10-K that
addresses the
       following:
 Guy Bowker
Enstar Group LTD
July 12, 2019
Page 2

           Explain how you present commutations and buybacks in the incurred
loss and
           cumulative paid loss tables, particularly what determines the
calendar year within the
           tables in which these transactions are reflected, how the
re-estimated incurred losses
           are presented in calendar years within the tables subsequent to the
           commutation/buyback, and the absence of recasting prior year loss
development to
           remove commuted claims. Refer to discussion on page 2 of your
response under the
           heading "in our disclosure."
         Explain how your commutation/buyback strategy is considered in
determining your
           loss reserves recorded as part of business combinations/non-life run
off retroactive
           reinsurance contracts and in subsequently revising those estimates.
         Explain how your commutation/buyback strategy is considered in
determining the
           amortization of your fair value adjustment/deferred charge assets
and the subsequent
           adjustment thereto. Refer to Notes 2(n) and (o) to your financial
statements.
         With reference to your statement that "once commutations and buybacks
are agreed
           they are removed from the actuarial data sets and do not have an
impact on the setting
           of reserves for ongoing business," explain whether your
commutations/buybacks are
           limited to being directly with the insureds/reinsureds, your basis
for concluding that
           commutations/buybacks represent the settlement/development of claims
and why,
           given your normal business practice of entering into commutations
and buybacks, it is
           appropriate to remove them from the actuarial data sets and thus not
have an impact on
           the ongoing reserve estimates .
         Explain how reinsurance recoveries impact the cumulative paid loss
tables, as well as
           the table, Annual Percentage Payout of Incurred Losses since Year of
Acquisition. In
           particular, clarify that reinsurance recoveries are reported in the
year received as
           opposed to the year the related claim payment was made.
         Explain how you present inter-company reinsurance arrangements that
are eliminated
           upon consolidation in the incurred loss and cumulative paid loss
tables, particularly
           the impact of the KayLa Re acquisition in 2018. Refer to discussion
on page 3 of your
           response.
         Regarding the "2008 and prior accident years" line item within the
incurred loss and
           cumulative paid loss tables that you have provided voluntarily,
explain the issues in
           presenting this information and the impact of those issues within
the acquisition year
           and the subsequent calendar years. Refer to discussion in the last
two bullets on page 3
           of your response. We acknowledge that, to the extent some or all of
these issues are
FirstName resolved during Bowker to your additional refinement of the data and
your
            LastNameGuy 2019 due
Comapanypresentation changesLTD result, the disclosure in your 2019 10-K may
change
            NameEnstar Group as a
July 12, 2019 Page 2 from the proposed revised disclosure you provide us.
           accordingly
FirstName LastName
 Guy Bowker
FirstName LastNameGuy Bowker
Enstar Group LTD
Comapany NameEnstar Group LTD
July 12, 2019
Page 3
July 12, 2019 Page 3
FirstName LastName
       You may contact Frank Wyman at 202-551-3660 or Jim Rosenberg at
202-551-3679 with
any questions.



                                                      Sincerely,

                                                      Division of Corporation
Finance
                                                      Office of Healthcare &
Insurance