SecProbe.io

Mail Stop 4720

August 7, 2017

Yu Cong
Chief Financial Officer
Yirendai Ltd.
10/F, Building 9,91 Jianguo Road
Chaoyang District, Beijing 100022
The People’s Republic of China

Re: Yirendai Ltd.
Form 20 -F for the Fiscal Year Ended December 31, 2016
Filed  April 24, 2017
  File No. 001 -37657

Dear Mr. Cong :

We have reviewed your filing an d have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.

Please respond to these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comments apply to  your facts and circumstances , please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

Form 20 -F for the Fiscal Year Ended December 31, 2016

Fluctuations in exchange rates could have a material adverse effect on our results of operations
and the price of our ADSs. , page 36

1. Please revise future filings to correctly identify your reporting currency as Renminbi .

Item 5. Operating and Financial Review and Prospects, page 83

2. Please revise future filings to discuss the changes in financial position for the periods
presented.

Yu Cong
Yirendai Ltd.
August 7, 2017
Page 2

 3. Please provide us, and revise future filings to disclose, an analysis of the loans
outstanding at each period end presented, including but not limited to:

 Loan balance outstanding by grade and channel; and
 Average maturity by grade and by channel.

Please discuss and analy ze any significant changes o r trends.

4. Please tell us, and revise future flings to disclose , your average customer acquisition costs
for each period presented and discuss and analyze any significant trends.

5. Please provide us, and revise future filings to disclose , key operating metr ics related to
your investors including, but not limited to:

 the reinvestment rate of existing investors;
 the number of new investors that made an investment during each quarter  in the most
recent fiscal year and during the prior fiscal years ; and
 the total number of investors that made an investment during each quarter  in the most
recent fiscal year and during the prior fiscal years. .

6. Please provide us, and revise future filings to disclose , key operating metrics related to
your borrowers includin g, but not limited to:

 the re -borrowing rate of existing borrowers;
 the number of new borrowers  that borrowed money during each  quarter  in the most
recent fiscal year and during the prior fiscal years ; and
 the total number of borrowers that borrowed mone y during each quarter  in the most
recent fiscal year and during the prior fiscal years .

7. We note disclosure related to concentrations of credit risk on page F -25 and your
disclosure that referrals from CreditEase’s  on-the-ground sales network account for a
majority of your borrowers and loan volume.  Please ensure you identify, quantify and
analyze known trends, demands, commitments, events and un certainties related to
borrowers , investors or referring entities, whe ther affiliated or unaffiliated, that are
reasonably likely to have a material impact on your financial results o r business.  Refer to
Item 303 of Regulation S -K for guidance.

Transaction Fees, page 91

8. Please provide us, and revise future filings to disc lose, the average yield (i.e.
revenue/average balance of loans) by channel  for the periods presented .

Yu Cong
Yirendai Ltd.
August 7, 2017
Page 3

 Service Fees, page 92

9. Please tell us , and revise future filings to disclose , the approximate percentage of
investors that use the automated investing t ool and the percentage that use the self -
directed investing tool.

Consolidated Financial Statements

Consolidated Balance Sheets as of December 31, 2015 and 2016, page F -3

10. We note that your consolidated balance sheets include RMB1.2 million of availabl e-for-
sale investments as of December 31, 2016.  For this same period end, we note that total
available -for-sale investments of the consolidated VIE companies, as disclosed on page
F-14, was RMB498,000  and that there were no available -for-sale investments included in
your Consolidated ABFE VIE disclosures on page F -16 or your Yirendai Ltd disclosures
on page F -13.  Please explain the difference and revis e future filings as necessary.

Notes to the Conso lidated Financial Statements for the years ended December 31, 2014, 2015
and 2016

Note 2. Summary of Significant Accounting Policies

Significant risks and uncertainties – Concentration of credit risk, page F -25

11. Please revise future filings to disclose if your cash deposits with financial institutions
located in the PRC are covered by insurance.

Note 5. Investments, page F -32

12. We note your disclosure that as of December 2016, the Company’s available -for-sale
investments consisted of wealth management pr oducts that have flexible holding horizon
and that the changes in fair value of these investments for the years ended December 31,
2015 and 2016 were nil.  Please provide us, and revise future filings, to include the
information required by ASC 320 -10-50-1A through 3, by major security type.

Note 7. Accrued Expenses and Other Liabilities, page F -33

13. On page 107, you disclose that your accrued expenses and other liabilities include
primarily funds payable to investors or borrowers.  However, in the detail o f accrued
expenses and other liabilities in Note 7 on page F -33, other types of payables comprise
most of the balance.   Please quantify for us the amount of funds payable to investors or
borrowers for the periods presented and tell us where the amounts ar e presented in your
balance sheet.  Please revise future filings accordingly.

Yu Cong
Yirendai Ltd.
August 7, 2017
Page 4

 Note 1 5 – Commitments and conting encies, Contingencies, page F -42

14. Specifically related to your disclosure on page 37 that you have not made adequate
employee benefit payments  and may be required to make up the contributions as well as
to pay late fees and fines and in general related to class action lawsuits any other potential
regulatory or other significant loss contingencies, in accordance with ASC 450 -20-50,
please revise future filings to disclose:

 the amount or range of reasonably possible losses in addition to amounts accrued, or
 that reasonably possible losses cannot be estimated, or
 that any reasonably possible losses in addition to amounts accrued is not material t o
your financial statements.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Benjamin Phippen, Staff Accountant  at (202) 551 -3697 or me at (202)
551-3437  if you have questions regarding our comments.

Sincerely,

 /s/ Michael Volley

Michael Volley
Staff Accountant
Office of Financial Services