SEC Company Response from X Financial (XYF) (CIK 0001725033) (XYF) — Sep 12, 2018
X Financial (XYF) (CIK 0001725033)
Date: Sept. 12, 2018 · CIK: 0001725033 · Accession: 0001104659-18-056337
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-227065
Letter
Office of Financial Services Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549
Dear Mr. Clampitt:
On behalf of our client, X Financial (the “Company”), a company incorporated under the laws of the Cayman Islands, we submit to the staff (the “Staff”) of Securities and Exchange Commission (the “Commission”) this letter in connection with the Company’s registration statement on Form F-1 initially filed on August 28, 2018, as amended on September 10, 2018 (the “Registration Statement”). Concurrently with the submission of this letter, the Company is filing its amendment No. 2 to the Registration Statement (the “Amended Registration Statement”) and certain exhibits via EDGAR with the Commission.
To facilitate your review, we have separately delivered to you four courtesy copies of the Amended Registration Statement, marked to show changes to the Registration Statement, and two copies of the submitted exhibits.
The Company plans to request that the Staff declare the effectiveness of the Registration Statement on September 18, 2018 and file the joint acceleration requests on September 14. As such, we would be grateful if the Staff could respond promptly with additional comments, if any, on the Amended Registration Statement prior to the contemplated public offering and greatly appreciate the Staff’s continuing assistance and support in meeting the timetable.
* * * *
If you have any questions regarding this submission, please contact me at +86-10-8567-5005 (li.he@davispolk.com) and/or Ran Li at +86-10-8567-5013 (ran.li@davispolk.com).
Yours sincerely,
/s/ Li He
Li He
cc: Mr. Yue (Justin) Tang, Chief Executive Officer
Mr. Jie (Kevin) Zhang, Chief Financial Officer
X Financial
Ms. Dan Ouyang, Esq.
Mr. Weiheng Chen, Esq.
Mr. Steven V. Bernard, Esq.
Wilson Sonsini Goodrich & Rosati
Deloitte Touche Tohmastu Certified Public Accountants LLP
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CORRESP 1 filename1.htm New York Paris Northern California Madrid Washington DC Tokyo São Paulo Beijing London Hong Kong Davis Polk & Wardwell LLP 美 国 达 维 律 师 事 务 所 86 10 8567 5000 tel 2201 China World Office 2 86 10 8567 5123 fax 1 Jian Guo Men Wai Avenue 北京市朝阳区建国门外大街1号 Chaoyang District 国贸写字楼2座2201室 Beijing 100004 September 12, 2018 Re: X Financial (CIK No. 0001725033) Registration Statement on Form F-1 (File no. 333-227065) Mr. Michael Clampitt Office of Financial Services Division of Corporation Finance U.S. Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Dear Mr. Clampitt: On behalf of our client, X Financial (the “Company”), a company incorporated under the laws of the Cayman Islands, we submit to the staff (the “Staff”) of Securities and Exchange Commission (the “Commission”) this letter in connection with the Company’s registration statement on Form F-1 initially filed on August 28, 2018, as amended on September 10, 2018 (the “Registration Statement”). Concurrently with the submission of this letter, the Company is filing its amendment No. 2 to the Registration Statement (the “Amended Registration Statement”) and certain exhibits via EDGAR with the Commission. To facilitate your review, we have separately delivered to you four courtesy copies of the Amended Registration Statement, marked to show changes to the Registration Statement, and two copies of the submitted exhibits. The Company plans to request that the Staff declare the effectiveness of the Registration Statement on September 18, 2018 and file the joint acceleration requests on September 14. As such, we would be grateful if the Staff could respond promptly with additional comments, if any, on the Amended Registration Statement prior to the contemplated public offering and greatly appreciate the Staff’s continuing assistance and support in meeting the timetable. * * * * If you have any questions regarding this submission, please contact me at +86-10-8567-5005 (li.he@davispolk.com) and/or Ran Li at +86-10-8567-5013 (ran.li@davispolk.com). Yours sincerely, /s/ Li He Li He cc: Mr. Yue (Justin) Tang, Chief Executive Officer Mr. Jie (Kevin) Zhang, Chief Financial Officer X Financial Ms. Dan Ouyang, Esq. Mr. Weiheng Chen, Esq. Mr. Steven V. Bernard, Esq. Wilson Sonsini Goodrich & Rosati Deloitte Touche Tohmastu Certified Public Accountants LLP 2