commercial paper ratings to ACE Ltd. and to ACE INA Holdings Inc. yesterday.

It found ACE's operating performance was "excellent'' as measured by three-year average return on revenue at 33 percent, return on earnings of 17 percent and return on assets at eight percent.

ACE's diversification programme over the past five years had "led to a meaningful spread of risk compared with its past reliance on excess liability and directors and officers liability insurance'', S&P found.

Pending acquisitions of CIGNA Property & Casualty Insurance Co. and Capital Re Corp. added significant operations at Lloyds of London, in the property catastrophe reinsurance arena and now in the global property casualty and financial reinsurance markets, it found.

"The integration risk of this strategy remains a risk factor for the financial strength of the members of the ACE group, offsetting the very strong operating performance of most core operations.'' And by diversifying its businesses and the use of reinsurance ACE Ltd. had lessened its volatility of results, although this was still a risk factor due to the underlying high-severity, low frequency nature of traditional ACE operations.

Capital adequacy for ACE was also deemed "very strong''.

"Capital adequacy for the ACE companies, prior to the acquisition of the property and casualty operations of the CIGNA Corp. remains very strong at March 31, 1999,'' it said.

"Capital adequacy has consistently been at or above the double-A rating category except in the period following large acquisitions.'' Promoted: Bermuda insurance giant ACE Limited yesterday announced the promotion of Niranjalie Romeo (above) to the new position of audit manager of Bermuda operations. Bermudian Mrs. Romeo joined ACE two years ago as a senior auditor and after the promotion she will be responsible for managing audits of ACE's Bermuda operations including Tempest Re, ACE Bermuda and ACE Limited.

Before joining ACE Mrs. Romeo worked at Arthur Andersen & Co. for three years as an audit senior.