SEC Company Response from X Financial (XYF) (CIK 0001725033) (XYF) — Sep 17, 2018
X Financial (XYF) (CIK 0001725033)
Date: Sept. 17, 2018 · CIK: 0001725033 · Accession: 0001104659-18-057054
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File numbers found in text: 001-38652
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CORRESP 1 filename1.htm September 17, 2018 Deutsche Bank Securities Inc. 60 Wall Street, 2nd Floor New York, New York 10005 United States Morgan Stanley & Co. International plc 25 Cabot Square Canary Wharf London E14 4QA United Kingdom as representatives of the several underwriters VIA EDGAR 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 Re: X Financial (CIK No. 0001725033) Registration Statement on Form F-1, as amended (File No. 333- 227065) Registration Statement on Form 8-A (File No. 001-38652) Dear Mr. Clampitt: We hereby join X Financial (the “Company”) in connection with its request for acceleration of the above-referenced Registration Statements, requesting effectiveness at 4:00 p.m., Eastern Time, on September 18, 2018, or as soon thereafter as practicable. Pursuant to Rule 460 of the General Rules and Regulations promulgated under the Securities Act of 1933, as amended, we wish to advise you that, through the date hereof, approximately 722 copies of the Company’s preliminary prospectus dated September 12, 2018 were distributed to prospective underwriters, institutional investors, dealers and others. The undersigned advise that the underwriters have complied and will continue to comply with Rule 15c2-8 under the Securities Exchange Act of 1934, as amended. [Signature page follows] Very truly yours, As representative of the several underwriters DEUTSCHE BANK SECURITIES INC. By: /s/ Francis Windels Name: Francis Windels Title: Managing Director By: /s/ Stephen Lambrix Name: Stephen Lambrix Title: Director [Signature Page to Underwriters’ Acceleration Request] Very truly yours, As representative of the several underwriters MORGAN STANLEY & CO. INTERNATIONAL PLC By: /s/ Daniel Wetstein Name: Daniel Wetstein Title: Managing Director [Signature Page to Underwriters’ Acceleration Request]