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Correspondence 0001193125-24-204390 from Upstart Holdings, Inc. (UPST) (CIK 0001647639) (UPST)

Upstart Holdings, Inc. (UPST) (CIK 0001647639)
Date: Aug. 21, 2024 · CIK: 0001647639 · Accession: 0001193125-24-204390

AI Filing Summary & Sentiment

File numbers found in text: 001-39797

Referenced dates: August 13, 2024

Date
August 21, 2024
Author
/s/ Allison Spinner
Form
CORRESP
Company
Upstart Holdings, Inc. (UPST) (CIK 0001647639)

Letter

VIA EDGAR SUBMISSION Securities and Exchange Commission Division of Corporation Finance Office of Technology Attention: Susan Block Christian Windsor Re: Upstart Holdings, Inc. Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2023 File No. 001-39797

Dear Ms. Block and Mr. Windsor:

In the comment letter (the “Comment Letter”) of the staff of the Securities and Exchange Commission (the “Staff”) dated August 13, 2024, the Staff requested that Upstart Holdings, Inc. (the “Company”) respond to the Staff’s comments regarding the above referenced Annual Report on Form 10-K (the “Form 10-K”) filed on February 15, 2024 (File No. 001-39797) within ten business days of receipt of the Comment Letter.

Pursuant to the Company’s request by telephone with Christian Windsor on August 20, 2024, the Company requests an extension of an additional ten business days so that the Company may devote the appropriate amount of time and resources to ensure a sufficient response. The Company plans to provide a response to the Comment Letter on or before September 11, 2024.

Please do not hesitate to call me at (650) 565-3765 or Shannon Delahaye at (650) 565-3045 with any questions.

Sincerely,
/s/ Allison Spinner

Show Raw Text
CORRESP
1
filename1.htm

CORRESP

 Wilson Sonsini Goodrich & Rosati
Professional Corporation

 650 Page Mill Road
Palo Alto, California 94304-1050

 O: 650.493.9300
F: 866.974.7329

 August 21, 2024

 VIA
EDGAR SUBMISSION

 Securities and Exchange Commission

Division of Corporation Finance

 Office of Technology

100 F Street, N.E.

 Washington, D.C. 20549

Attention:
 Susan Block

Christian Windsor

Re:
 Upstart Holdings, Inc.

Annual Report on Form 10-K for the Fiscal Year Ended December 31, 2023

File No. 001-39797

Dear Ms. Block and Mr. Windsor:

 In
the comment letter (the “Comment Letter”) of the staff of the Securities and Exchange Commission (the “Staff”) dated August 13, 2024, the Staff requested that Upstart Holdings, Inc. (the
“Company”) respond to the Staff’s comments regarding the above referenced Annual Report on Form 10-K (the “Form 10-K”)
filed on February 15, 2024 (File No. 001-39797) within ten business days of receipt of the Comment Letter.

Pursuant to the Company’s request by telephone with Christian Windsor on August 20, 2024, the Company requests an extension of an
additional ten business days so that the Company may devote the appropriate amount of time and resources to ensure a sufficient response. The Company plans to provide a response to the Comment Letter on or before September 11, 2024.

Please do not hesitate to call me at (650) 565-3765 or Shannon Delahaye at (650) 565-3045 with any questions.

Sincerely,

/s/ Allison Spinner

Allison Spinner

cc:
 Sanjay Datta, Upstart Holdings, Inc.

Scott Darling, Upstart Holdings, Inc.

Christopher Ing, Upstart Holdings, Inc.

Cynthia Moon, Upstart Holdings, Inc.

Jeffrey Saper, Wilson Sonsini Goodrich & Rosati, P.C.

Shannon Delahaye, Wilson Sonsini Goodrich & Rosati, P.C.

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