April 3, 2019

Mac Armstrong
Chief Executive Officer
Palomar Holdings, Inc.
7979 Ivanhoe Avenue, Suite 500
La Jolla, CA 92037

       Re: Palomar Holdings, Inc.
           Amendment No. 1 to Registration Statement on Form S-1
           Filed April 1, 2019
           File No. 333-230346

Dear Mr. Armstrong:

      We have reviewed your amended registration statement and have the
following
comments. In some of our comments, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply to your facts
and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

       After reviewing any amendment to your registration statement and the
information you
provide in response to these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our March 26,
2019 letter.

Amendment No. 1 to Form S-1 filed April 1, 2019

Prospectus Summary
Recent Developments, page 9

1.     We refer to your revised disclosures regarding the entrance into a new
earthquake
       partnership, which entails your assumption of earthquake policies, and
that carrier
       partnerships are a strategic focus for you. As this disclosure indicates
that you are not
       initially writing these policies, please balance your disclosure in the
first paragraph on
       page 5, and elsewhere as appropriate, to explain that your granular
underwriting process
       does not apply to all of your policies, such as policies acquired
through partnerships where
       the partner initially writes the policies.
 Mac Armstrong
FirstName LastNameMac Armstrong
Palomar Holdings, Inc.
Comapany NamePalomar Holdings, Inc.
April 3, 2019
Page 3,
April 2 2019 Page 2
FirstName LastName
Our certificate of incorporation and bylaws provide that the Court of Chancery
of the State of
Delaware. . ., page 42

2.       We note your response to prior comment 5 and your revised disclosures,
and refer also to
         our prior comment 6 in our comment letter dated February 8, 2019.
Please revise your
         disclosure to state whether the provision applies to actions arising
under the Securities
         Act. In that regard, we note that Section 22 of the Securities Act
creates concurrent
         jurisdiction for federal and state courts over all suits brought to
enforce any duty or
         liability created by the Securities Act or the rules and regulations
thereunder. If this
         provision applies to claims arising under the Securities Act, then
please disclose that there
         is uncertainty with respect to whether a court would enforce this
provision and state that
         shareholders will not be deemed to have waived your compliance with
the federal
         securities laws and the rules and regulations thereunder.
Capitalization, page 49

3.       Please revise to include your pro forma balance sheet information at
December 31, 2018.
Executive Compensation
Outstanding Equity Awards at Fiscal Year-End, page 134

4.       We note your revised disclosure in response to prior comment 6 and
your statement in
         footnote 2 that all of the awards are subject to the performance
condition of a liquidity
         event. Please revise your table to include the column disclosing the
number of securities
         underlying unexercised unearned awards or otherwise confirm in
footnote 3 that the
         number of shares of common stock awarded to the NEOs were the same as
the number of
         underlying shares as of December 31, 2018 and 2017. Refer to Item
402(p)(2)(iv) of
         Regulation S-K.
Principal Stockholders, page 139

5.       We acknowledge your revised disclosure in response to prior comment 7.
However, your
         disclosure in the second paragraph continues to indicate that certain
of your calculations
         are based on December 31, 2018. Please revise accordingly.
 Mac Armstrong
FirstName LastNameMac Armstrong
Palomar Holdings, Inc.
Comapany NamePalomar Holdings, Inc.
April 3, 2019
Page 3,
April 3 2019 Page 3
FirstName LastName
       You may contact Bonnie Baynes at 202-551-4924 or Lisa Vanjoske at
202-551-3614 if
you have questions regarding comments on the financial statements and related
matters. Please
contact Dorrie Yale at 202-551-8776 or Mary Beth Breslin at 202-551-3625 with
any other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Healthcare
& Insurance
cc:      Michael S. Kagnoff, Esq. - DLA Piper LLP (US)