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CORRESP
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FINTECH
SCION LIMITED

M
Floor & 1st Floor

No.
33 Jalan Maharajalela

50150,
Kuala Lumpur, Malaysia

August
28, 2024

VIA
EDGAR

United
States Securities and Exchange Commission

100
F. Street, NE

Washington,
DC 20549

    Attention:

    Rucha
    Pandit

    Dietrick
    King

    Scott
    Stringer

    Rufus
    Decker

    Re:

    Fintech
    Scion Limited

    Form
    10-K for Fiscal Year Ended December 31, 2023

    Amendment
    No. 3 to Form 10-K for Fiscal Year Ended December 31, 2023

    File
    No. 000-55655

Dear
Ladies and Gentlemen:

This
letter sets forth responses on behalf of Fintech Scion Limited, a Nevada corporation (the “Company”), to the comments
received from the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) set
forth in your letter dated June 11, 2024 (“Comment Letter”) regarding the Company’s Form 10-K for Fiscal Year
Ended December 31, 2023, as amended (the “Form 10-K”).

For
the convenience of the Staff, each comment from the Comment Letter corresponds to the numbered paragraphs in this letter and is
restated prior to the response to such comment.

Form
10-K for Fiscal Year Ended December 31, 2023

Part
I

Item
1. Business

Overview,
page 1

    1.

    With
    a view to providing more balanced disclosure, please disclose here the amount of your revenue for the most recently completed
    fiscal year and your net income/loss for the most recently completed fiscal year.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has updated the Form 10-K to disclose the amount of our revenue
    for the most recently completed fiscal year and our net loss for the most recently completed fiscal year. These revisions
    appear on page 4 and page 42 of the Form 10-K.

    2.

    Please
    clarify here that you currently operate in, and derive the bulk of your revenue from, the United Kingdom and Malaysia.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has
revised the Form 10-K to clarify that we currently operate in and derive the bulk of our revenue from the United Kingdom and Malaysia.
These revisions appear on page 3, page 4, page 41 and page 42 of the Form 10-K.

    3.

    Please
    balance the aspirational statements in this section with details about your actual business operations. For example, in the
    fourth paragraph, where you state your “current clientele encompasses an array of enterprises and organizations, spanning
    varied sectors,” please describe the industry sectors and types of customers you serve. If possible, please provide specific
    examples. In addition, in the same paragraph, please identify the “specific subset of online businesses that grapple
    with establishing and maintaining physical bank accounts across multiple territories” that you are referring to
    and explain why you think this is notable. Please make conforming revisions throughout the prospectus.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the Form 10-K to specifically describe the industry
    sectors and types of customers we serve. These revisions appear on page 3 and page 41 of the Form 10-K. In addition, we have
    deleted the reference to the “specific subset of online businesses that grapple with establishing and maintain bank
    accounts across multiple territories” that we referred to in the same paragraph and have made conforming revisions throughout
    the Form 10-K.

Corporate
History and Structure, page 4

    4.

    Please
    revise the diagram of your corporate structure on page 5 to add ownership percentages.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the diagram of our corporate structure to add
    ownership percentages. The revised diagram appears on page 5 of the Form 10-K.

Market
Opportunity, page 12

    5.

    We
    note your representations on pages 13-14 that the Payment Gateway Market in the Technology Layer is “expected to
    grow to $174.4 billion in 2027” and the Payment Processing Market in the Payment Layer is “expected to grow to $116.2
    billion in 2027.” Please revise to disclose the sources of these statements. In addition, please provide context for
    the significance to you of the overall dollar value of these markets by clarifying how much of them you believe you would
    be in a position to address in light of your resources.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has
revised these representations in the Form 10-K to and disclosed the sources of these revised statements and provide context for the significance
to us of the overall dollar value of these markets by clarifying how much of them we believe we would be in a position to address in light
of our resources. These revisions appear on page 12, page 13, page 14 and page 15 of the Form 10-K.

Government
Regulations, page 17

    6.

    We
    note your references here to “the Bank.” However, this entity does not appear to be discussed or otherwise referenced
    within your registration statement. Please advise or revise to describe or define this entity.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the Form 10-K to remove all references to “the
    Bank.” This revision appears on page 18 and page 19 of the Form 10-K..

 Item 1A. Risk Factors, page 17

    7.

    We
    note your disclosure on page F-16 that “inflationary pressures also caused [y]our forecasted expenses to increase”
    during the fiscal year ended December 31, 2023. To the extent applicable, please update your risk factors to disclose how
    recent inflationary pressures have materially impacted your business and operations. As examples only, identify the types
    of inflationary pressures you are facing and how your business has been affected.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the Form 10-K to include a risk factor to disclose
    how recent inflationary pressures have materially impacted our business and operations. This risk factor appears under the
    heading “we may operate in jurisdictions with historically high rates of inflation” on page 21 of the Form 10-K.

    8.

    We
    note your disclosure on page F-16 that your “discounted cash flows utilized a higher risk-adjusted discount rate
    for the 2023 impairment test, primarily due to central banks raising interest rates in 2023.” To the extent applicable,
    please update your risk factors to disclose the material impact of any rate increases on your operations and how your business
    has been affected. For example, describe whether your borrowing costs have recently increased or are expected to increase
    and your ability to pass along your increased costs to your customers.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the Form 10-K to include a risk factor to disclose
    the material impact of any rate increases on our operations and how our business has been impacted. This risk factor appears
    under the heading “general fluctuations in interest rates may adversely affect our business and operations” on
    page 21 of the Form 10-K.

    9.

    Please
    add a risk factor to address the risks associated with certain of your shareholders potentially having the ability,
    now or in the future, to exercise significant control over your company.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and have added a risk factor to address the risks associated with
    certain of our shareholders potentially having the ability, now or in the future, to exercise significant control over our
    company. This risk factors appears under the heading “certain shareholders may exercise significant control over our
    business policies” on page 29 of the Form 10-K.

We
have a limited operating history with financial results that may not be indicative of future performance . . . page 17

    10.

    Please
    revise the risk factor and risk factor heading to clearly disclose your history of net losses.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the risk factor and risk factor heading to clearly
    disclose our history of net losses. The revised risk factor appears on page 20 of the Form 10-K.

We
are subject to chargeback and refund liability risk when our merchants refuse to or cannot reimburse chargebacks . . . page 27

    11.

    We
    note your disclosure here that you “are currently, and will continue to be, exposed to certain risks associated with
    chargebacks and refunds in connection with payment card fraud or relating to the goods or services provided by our merchant
    customers.” To the extent your business has been materially affected by risks associated with such chargebacks and refunds,
    please state as much.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the risk factor to disclose the extent to which
    our business has been materially affected by risks associated with chargebacks and refunds. This revision appears on page
    31 of the Form 10-K.

Item
7. Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations, page 35

    12.

    Please
    provide a more robust analysis of your results of operations. For example, expand your discussion of the impact of the restructuring
    transactions on cost of sales and the changes in selling expenses and general and administrative expenses to address the underlying
    reasons for changes in qualitative terms. Please refer to Item 303(b) of Regulation S-K.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the Form 10-K to provide a more robust analysis
    of our results of operations. These revisions appear beginning on page 43 through page 46 of the Form 10-K.

Item
13. Certain Relationships and Related Transactions, page 48

    13.

    If
    any two of these entities (the Company, Fintech, FintechAsia and/or CICO) had any common owners and/or related parties before
    their respective transactions, please disclose their names, any positions held at each entity and the percentages of ownership
    in each entity before and after the transactions. Also, clearly disclose any other related party relationships between each
    of these entities. For example, based on your disclosure on page F-9, it appears that CICO and the Company may have common
    ownership, but who the common owners are, the extent of common ownership and any other related party relationships are not
    disclosed.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the Form 10-K to disclose, to the extent any two
    of these entities had any common owners and/or related parties before their respective transactions, the names, positions
    held at each entity and the percentage of ownership in each entity before and after their transactions. These revisions appear
    on page 58, page 59 and page 60 of the Form 10-K.

General

    14.
    In
    an appropriate section of this filing, please provide a fuller description of your core business activities. In doing
    so, please be as specific as possible.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the Form 10-K to provide a fuller description
    of our core business activities. These revisions appear on page 6 of the Form 10-K.

    15.

    In
    an appropriate section of this filing, please disclose a breakdown of revenue for each of your major services. For example,
    it appears that you generate revenue from six services: payment services; business accounts; SEPA and SWIFT payments; foreign
    exchange conversion; acquirer services; and whitelabelling. However, it is not clear how much each of these services contributes
    to your revenue. If any of these services are currently dormant or aspirational, or if you have not yet generated revenue
    from them, please make this clear in the disclosure.

    RESPONSE:
    The
    Company respectfully acknowledges the Staff’s comment and has revised the Form 10-K to disclose a breakdown of revenue
    for each of our major services. This revision appears on page 43 of the Form 10-K.

Amendment
No. 3 to Form 10-K for Fiscal Year Ended December 31, 2023

Audited
Consolidated Financial Statements, page F-1

    16.

    Please
    confirm that the statements of operations and comprehensive income (loss), stockholders’ equity, and cash flows for periods
    prior to November 30, 2022 are those of Fintech (the accounting acquirer) and do not include any of the Company’s or FintechAsia’s
    operations, changes in equity (except for the Company’s capital structure) or cash flows. Otherwise, tell us how your accounting
    for the November 30, 2022 reverse acquisition complies with GAAP. Also, tell us why the 101.667 million shares issued to Fintech
    (per page F-9) are not reflected as outstanding in your statements of stockholders’ equity just before the reverse merger
    with the 97.076 million shares effectively issued to the Company (per page F-9) being reflected as issued on November 30,
    2022. Refer to ASC 805-40-45.

    RESPONSE:
    The
                                         Company respectfully acknowledges the Staff’s comment and has restated the financial
                                         statements appearing on pages F-3 to F-7 to comply with GAAP standards, where the 2022
                                         financial results (retained earnings) of the Company and its subsidiary, FintechAsia
                                         only include December 2022 results (excluding January 2022 to November 2022 earnings).

Please
        refer to our responses in question 17 for the accounting standard of reverse acquisition.

        Regarding
        the issuance of shares to FintechAsia and Fintech is reflected in our Statements of Stockholders’ Equity on Page
        F-5 where the Company issued 193,333,333 shares in the financial year 2022 for the acquisitions of FintechAsia and Fintech.
        The Company issued 91,666,667 shares to FintechAsia’s shareholders and 101,666,666 shares to Fintech’s shareholders.

        Therefore,
        the outstanding shares of the Company as of December 31, 2022, increased from 5,409,310 shares (after the effectiveness
        of the 10-to-1 reverse stock split on April 11, 2022) to 198,742,643 shares.

Consolidated
Balance Sheet, page F-4

    17.

    Please
    tell us your basis in GAAP for presenting a line item for merger reserves of $55 million on your balance sheet. Cite the GAAP
    literature you are relying upon and explain how you are applying it.

 RESPONSE: Background

In
early Q1 of 2022, both the management of Fintech Scion Limited (UK) (“FSLUK”) and FintechCashier Asia P.L.C.
(previously known as HWGG Capital P.L.C. (“HWGG”)), met to discuss the possibility of business collaboration.
Upon understanding each other’s business, both companies decided to merge their businesses due to their similar business
activities.

During
these discussions, the management of HWGG informed FSLUK that HWGG was in talks to be acquired by Fintech Scion Limited (previously
known as HWGC Holding Limited (“HWGC”), a Nevada company quoted under OTC Markets Group. The management of
HWGG extended an invitation to FSLUK to be part of this acquisition by HWGC, seeing the potential benefits of consolidating their
business activities under one umbrella. HWGG and HWGC were under common control, as the former major shareholder of HWGG, Lim
Chun Hoo, who held 5