September 21, 2018

Anthony McKiernan
Chief Financial Officer
MBIA INC
1 Manhattan Road
Suite 300
Purchase, NY 10577

       Re: MBIA INC
           Form 10-K for the Fiscal Year Ended December 31, 2017
           Filed March 1, 2018
           File No. 001-09583

Dear Mr. McKiernan:

       We have reviewed your August 9, 2018 response to our comment letter and
have the
following comments. In our comment, we may ask you to provide us with
information so we
may better understand your disclosure.

       Please respond to this 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 this comment, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
July 31, 2018 letter.

Form 10-K for the Fiscal Year Ended December 31, 2017

Item 7. Management's Discussion and Analysis of Financial Condition and Results
of Operations
Results of Operations
Adjusted Book Value, page 36

1.    We acknowledge your response to our prior comment one. It is not clear to
us why MBIA
      Corp.'s book value whether positive or negative is excluded from adjusted
book value,
      which results in its complete nonrecognition from the consolidated
financial statements
      for purposes of adjusted book value. Please provide us a schedule of the
assets and
      liabilities of MBIA corp. and why each should be excluded from adjusted
book value. In
 Anthony McKiernan
MBIA INC
September 21, 2018
Page 2
         addition, regarding the schedule in your response whereby you arrive
at "Adjustment in
         ABV Reconciliation," confirm to us that the purpose of the columns
         labelled "Less: Amounts related to MBIA Corp. " and "Less:
Intercompany Eliminations"
         is solely to be consistent with your rationale for not recognizing
MBIA Corp.'s book value
         for purposes of adjusted book value.
       You may contact Christine Torney at 202-551-3652 or Jim Rosenberg at
202-551-3679
with any questions.



FirstName LastNameAnthony McKiernan                           Sincerely,
Comapany NameMBIA INC
                                                              Division of
Corporation Finance
September 21, 2018 Page 2                                     Office of
Healthcare & Insurance
FirstName LastName