December 17, 2004

 

 

Securities and Exchange Commission

Division of Corporation Finance

450 Fifth Street, N.W.

Washington D.C.  20549

 

 

 

 

 

 

Dear Ms. Doorn and Mr. Demarest:

 

We are submitting this letter in response to your letter, dated December 16, 2004, to Carl Mautz, Chief Financial Officer of Watson Wyatt & Company Holdings (the Company).  The response set forth below corresponds to the numbered paragraph in your letter.

 

In connection with our response, we acknowledge the following:

 

•                  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.

 

 

 

Notes to Consolidated Financial Statements

 

Note 16 - Discontinued Operations

 

1.              Related to prior comment 6, expand your disclosure in future filings to include the information contained in your response.  Please confirm to us that you will expand your disclosure.

 

We will expand our disclosure in future filings to include the information provided in response to prior comment 6.

 

 

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We believe we have addressed all of your comments.  Please contact me at (202) 715-7056 if you wish to discuss any of our responses.

 

Very Truly Yours,

 

 

 

Carl D. Mautz

Chief Financial Officer

Watson Wyatt and Company Holdings

 

cc:	Brian Lane, Esq.
	Walter W. Bardenwerper, Esq.
	Hong Nguyen, Esq.
	Peter L. Childs, Controller

 

 

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