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CORRESPONDENCE

 March 22, 2022

Mr. Mark Brunhofer

 Division of Corporation Finance

Office of Finance

 U.S. Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

U.S.A.

Re:
 Nomura Holdings, Inc.

 Form 20-F for the Fiscal Year Ended March 31, 2021

 Filed June 25, 2021

 File
No. 001-15270

Dear Mr. Brunhofer:

 We refer to the comment
letter from the Staff of the Securities and Exchange Commission (“SEC”), dated February 22, 2022 (the “Letter”) with respect to the annual report on Form 20-F of Nomura Holdings, Inc.
(“Nomura”) for the fiscal year ended March 31, 2021 filed with the SEC on June 25, 2021 (the “Form 20-F”). Our responses to the Staff’s comments in the Letter are set forth
below. For your convenience, we have included the text of the Staff’s comments below and have keyed our responses accordingly.

 Form 20-F for the Fiscal Year Ended March 31, 2021

 Notes to the Consolidated Financial Statements

 Note 20: Affiliated companies and other equity-method investees:

NREH, page F-130

1.
 You disclose that you recognized an impairment charge during fiscal 2021 of ¥47,661 million related
to your equity method investment in Nomura Real Estate Holdings, Inc. (NREH) based on the period and extent to which the share price was below the carrying value. You also disclose that the difference between the carrying value of your investment in
NREH and the associated underlying equity in the net assets of NREH of ¥37,140 million was the result of the excess of the underlying equity in net assets over fair value of the investment at March 31, 2021. Please address the
following and reference for us, where appropriate, the authoritative literature you rely upon to support your accounting:

•

 We note that from September 2018 through March 31, 2021, excluding the decline between March 2020 and
December 2020, the stock price of NREH has been relatively stable and subsequently increased higher than before March 2020. Provide us your analysis supporting the period and extent to which the share price was below the carrying value to support
the recognition of the ¥47,661 million impairment charge during the fourth quarter of fiscal 2021, including why an impairment charge was not recorded for the periods ending March 31, 2019 and March 31, 2020 considering the stock
price activity during those periods, which other than the significant decline at the end of March 2020, appears to be reasonably consistent with trading beginning in December 2020.

•

 Disaggregate by investment, affiliated companies and other equity-method investees for which a quoted market
price is available and provide us a rollforward for the carrying amount of ¥340,909 million for each year from March 31, 2017 to March 31, 2021. At each year end tell us the fair value of each depicted investment, your ownership
percentage and the related underlying equity in net assets.

 Response:

Impairment of equity method investment in NREH

Nomura Real Estate Holdings, Inc. (“NREH”) is the holding company of the Nomura Real Estate Group which operates real estate
development, sales and other real estate related businesses. We held approximately 36% of the outstanding shares of NREH as of December 31, 2021. We have been applying the equity method of accounting to our investment in NREH since 2013. NREH
shares are actively traded on the Tokyo Stock Exchange (“TSE”). We periodically assess whether a loss in value of an equity method investment that is other than temporary exists as required by Accounting Standard Codification
(“ASC”) 323-10-35 for our investments in NREH by first comparing the carrying value of the investment as recognized in our consolidated financial statements
and its estimated fair value as suggested by the price of the shares of NREH on the TSE. When such estimated fair value is less than the carrying amount of our investment, we then consider whether such difference is other than temporary. In
assessing whether our investment is other than temporarily impaired, we not only consider the length of time that the fair value suggested by the TSE quoted share price is below the carrying amount of our investment, but, given the size of our
shareholding compared to the daily trading volume, other relevant information, such as unsolicited indications of interest from 3rd parties to purchase our investment, the unrealized gain on real estate held by NREH as calculated and disclosed by
NREH (which NREH calculates as the difference between the estimated market value and the carrying value of rental real estate held by NREH) and NREH’s financial results and outlook.

 1

 For the fiscal years ended March 31, 2019 and 2020, we did not recognize an impairment
loss on our investment in NREH because the decline in the TSE share price being below the carrying value of our investment was not considered to be other than temporary. This determination was based on: the historically volatile nature of the TSE
share price of NREH’s shares; the fact that the length of time that the fair value as suggested by the TSE share price was below the carrying value was not deemed prolonged, particularly for the fiscal year ended March 31, 2019;
NREH’s consistently growing operating revenue, operating profit, ordinary profit and EPS; the upward trend of unrealized gain of real estate held by NREH as calculated and disclosed by NREH (as described in the preceding paragraph) and the
receipt of multiple unsolicited indications of interest from 3rd parties to purchase our investment in 2019 and 2020. All of these factors indicated that the impairment was temporary, and the 3rd party indications of interest suggested a premium for our investment over the carrying value or the value as measured by the TSE share price.

Our determination that the impairment of our investment was temporary was unchanged between February 2020 and March 2020, during which time
the share price of NREH on the TSE declined significantly due to the impact of the Covid-19 pandemic. We determined at such time that the sharp decline in TSE share price caused by the Covid-19 pandemic was temporary considering that the TSE share price had been in a strong recovery trend during the period before the pandemic from late 2018 until early March 2020 and that NREH reported
year-over-year increases in its operating revenue, operating profit, ordinary profit and EPS as well as the continued upward trend of unrealized gain on real estate held by NREH as calculated and disclosed by NREH (as described in the second
preceding paragraph) in the fiscal year ended March 31, 2020.

 Similarly, as of September 30, 2020 and December 31, 2020,
we also continued to judge that the potential impairment was temporary and did not recognize an impairment loss because of the strong upward trend in the TSE share price following the dramatic declines in March 2020, which indicated that the
carrying value would be recoverable.

 In April 2021, NREH announced year-over-year declines in operating revenue, operating profit,
ordinary profit and EPS for the fiscal year ended March 31, 2021, as shown in the table below. It also announced its earnings forecasts for the fiscal year ending March 31, 2022. NREH’s financial forecasts, although in generally line
with historical results for the fiscal year ended March 31, 2020, did not indicate a rebound from the Covid-19 pandemic sufficient to offset the declines in the fiscal year ended March 31, 2021,
contrary to our expectations. This, coupled with no new unsolicited indications of interest from 3rd parties to purchase our investment and the prolonged length that the value of our investment
based on the TSE share price remained below the carrying value, led us judge that there was an other than temporary impairment, and, consequently, we recognized an impairment loss of JPY 47,661 million on our investment in NREH during the year
ended March 31, 2021, measured using the TSE share price.

 The following table shows recent key financial indicators of NREH to
support the above assessment.

 (JPY: billion, unless otherwise
stated)

Fiscal year ending March 31,

2018

2019

2020

2021

 2022 (NREH

forecast)

Operating revenue

623.7

668.5

676.4

580.6

680.0

Operating profit

76.6

79.6

81.9

76.3

77.0

Ordinary profit

68.0

69.3

73.0

65.9

72.5

EPS (JPY)

240.89

245.99

267.21

232.53

274.71

Estimated unrealized gain of real estate held(1)

181.9

206.3

209.6

209.6

-

(1)
 As calculated and disclosed by NREH. Calculated as the difference between the estimated market value and the
carrying values of rental real estate held by NREH.

 Roll-forward of our investments in affiliated companies and other
equity-method investees

 The following table presents a roll-forward of each of our investments in affiliated companies and other
equity-method investees for which a quoted market price is available for the fiscal years ended March 31, 2017 through to March 31, 2021. For each individual investment, the table shows the adjustment to the carrying value of the
investment over the fiscal year for application of the equity method of accounting, receipt of dividends or other distributions, other than temporary impairment losses, and full or partial disposals of the investment during the relevant fiscal year.

 2

Millions of yen

Fiscal year ended March 31

2017

2018

2019

2020

2021

Balance

Equity
method
adjustments

Dividends
received

Investment
disposal

Balance

Equity
method
adjustments

Dividends
received

Balance

Equity
method
adjustments

Dividends
received

Partial
investment
disposal

Balance

Equity
method
adjustments

Dividends
received

Impairment
losses

Balance

 Nomura Research Institute, Ltd.

207,603

20,844

(7,892
)

—

220,554

15,786

(8,275
)

228,066

12,942

(6,747
)

(84,636
)

149,625

24,566

(5,914
)

—

168,277

 Nomura Real Estate Holdings, Inc.

175,694

12,780

(4,534
)

—

183,940

16,576

(4,696
)

195,820

17,326

(5,020
)

—

208,125

17,350

(5,182
)

(47,661
)

172,632

 JAFCO Co., Ltd

29,642

1,083

(863
)

(29,862
)

—

—

—

—

—

—

—

—

—

—

—

—

 Takagi Securities Co., Ltd.

1,624

—

—

(1,624
)

—

—

—

—

—

—

—

—

—

—

—

—

 Total

414,563

34,707

(13,290
)

(31,485
)

404,494

32,363

(12,971
)

423,885

30,268

(11,767
)

(84,636
)

357,751

41,916

(11,096
)

(47,661
)

340,909

 For each individual investment in affiliated companies and other equity method investees where a quoted market
price is available, the relevant ownership percentage and related underlying equity in net assets of the investment, the carrying value of the investment as recognized in our consolidated financial statements and estimated fair value of the
investment, based on the relevant quoted market price as of March 31, 2017 through March 31, 2021.

Millions of yen, except percentages

As of March 31

2017

2018

2019

Carrying
amount

Fair value

Ownership %

Underlying
equity in net
assets

Carrying
amount

Fair value

Ownership %

Underlying
equity in net
assets

Carrying
amount

Fair value

Ownership %

Underlying
equity in net
assets

 Nomura Research Institute, Ltd.

207,603

380,692

37.2
%

150,763

220,554

463,399

38.5
%

153,233

228,066

462,480

39.3
%

152,197

 Nomura Real Estate Holdings, Inc.

175,694

115,447

34.1

164,654

183,940

162,721

34.6

173,369

195,820

137,652

35.3

184,963

 JAFCO Co., Ltd

29,642

32,284

19.5

34,201

—

—

—

—

—

—

—

—

 Takagi Securities Co., Ltd.

1,624

4,789

30.6

8,863

—

—

—

—

—

—

—

—

 Total

414,563

533,213

358,480

404,494

626,120

326,603

423,885

600,132

337,160

Millions of yen, except percentages

As of March 31

2020

2021

Carrying
amount

Fair value

Ownership%

Underlying
equity in net
assets

Carrying
amount

Fair value

Ownership %

Underlying
equity in net
assets

 Nomura Research Institute, Ltd.

149,625

397,983

28.8
%

88,315

168,277

595,757

28.6
%

107,706

 Nomura Real Estate Holdings, Inc.

208,125

113,685

35.9

197,363

172,632

172,632

36.1

209,772

 Total

357,751

511,667

285,678

340,909

768,389

317,477

 3

*    *    *    *    *

If you have any questions about this response letter, please contact the undersigned by mail.

Very truly yours,

 /s/ Takumi Kitamura

Takumi Kitamura

Chief Financial Officer

 cc:

 Michelle Miller

 (Division of Corporation Finance,

 U.S. Securities and Exchange Commission)

 Keiji Hatano

 (Sullivan & Cromwell LLP)

 Hiroki Matsumura

 (Ernst & Young ShinNihon LLC)

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