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July 21, 2023
Jiayuan Xu
Chief Financial Officer
FinVolution Group
Building G1, No. 999 Dangui Road
Pudong New District, Shanghai 201203
The People’s Republic of China
Re:FinVolution Group
Form 20-F for the Fiscal Year Ended December 31, 2022
Filed April 25, 2023
File No. 001-38269
Dear Jiayuan Xu:
            We have limited our review of your filing to the submission and/or disclosures as
required by Item 16I of Form 20-F and 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 business days by providing the requested
information or advise us as soon as possible when you will respond.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 172
1.We note your statement that you reviewed your register of members and public EDGAR
filings made by your shareholders in connection with your required submission under
paragraph (a).  Please supplementally describe any additional materials that were
reviewed and tell us whether you relied upon any legal opinions or third party
certifications such as affidavits as the basis for your submission.  In your response, please
provide a similarly detailed discussion of the materials reviewed and legal opinions or
third party certifications relied upon in connection with the required disclosures under
paragraphs (b)(2) and (3).
2.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party.  For

 FirstName LastNameJiayuan   Xu
 Comapany NameFinVolution Group
 July 21, 2023 Page 2
 FirstName LastName
Jiayuan   Xu
FinVolution Group
July 21, 2023
Page 2
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination.  In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
3.We note that your disclosures pursuant to Items 16I(b)(2), (b)(3) and (b)(5) are provided
for “FinVolution Group or the consolidated variable interest entities.”  We also note that
your list of principal subsidiaries, consolidated variable interest entities and subsidiaries of
consolidated variable interest entities in Exhibit 8.1 appears to indicate that you have
subsidiaries in the PRC, Hong Kong and countries outside China that are not included in
your VIEs.  Please note that Item 16I(b) requires that you provide disclosures for yourself
and your consolidated foreign operating entities, including variable interest entities or
similar structures.
•With respect to (b)(2), please supplementally clarify the jurisdictions in which your
consolidated foreign operating entities are organized or incorporated and provide the
percentage of your shares or the shares of your consolidated operating entities owned
by governmental entities in each foreign jurisdiction in which you have consolidated
operating entities in your supplemental response.
•With respect to (b)(3) and (b)(5), please provide the required information for you and
all of your consolidated foreign operating entities in your supplemental response.
            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.
            Please contact Jimmy McNamara at 202-551-7349 or Jennifer Thompson at 202-551-
3737 with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:       Haiping Li