SecProbe.io

July 18, 2019
Kun Dai
Chief Executive Officer
Uxin Limited
2-5/F, Tower E, LSHM Center
No. 8 Guangshun South Avenue
Chaoyang District
Beijing, 100102
People's Republic of China
Re:Uxin Limited
Form 20-F for Fiscal Year Ended December 31, 2018
Filed April 29, 2019
File No. 001-38527
Dear Mr. Dai:
            We have reviewed your filing 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.  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 Fiscal Year Ended December 31, 2018
Management's Discussion and Analysis of Financial Condition and Results of Operations
Selected Statements of Operations Items
Revenues, page 86
1.We note your disclosure on page F-27 that you do not charge transaction facilitation
services fees to car dealers for certain transactions without financing solutions attached.
However, on page F-23 of your Form F-1 filed June 22, 2018, you disclosed you did
charge a fee for these transactions.  Please tell us and address in future filings the
following:
•Revise to disclose the reason for the change in fees, including whether the change is
permanent or temporary.

 FirstName LastNameKun Dai
 Comapany NameUxin Limited
 July 18, 2019 Page 2
 FirstName LastNameKun Dai
Uxin Limited
July 18, 2019
Page 2
•Clearly disclose throughout that you do not charge a transaction facilitation fee in
arrangements where the buyer does not utilize your loan facilitation services.
•Revise disclosure on page 91 to discuss the impact this change has had on your
revenues during the reported periods.
Refer to Item 5.A of Form 20-F.
Gains/(losses) from guarantee liability, page 88
2.Please tell us how you considered disclosure of the notional balance or percentage of your
notional balance of your guarantee obligation by current loan to value categories, as trends
in this metric would appear to also impact the overall losses incurred as a result of your
guarantee obligation. Refer to Item 5.E.1.d of Form 20-F. Please advise and revise future
filings as applicable.
Contractual Obligations, page 108
3.Please tell us why you do not include amounts due pursuant to your convertible debt in
your contractual obligations table or explain why it is not included in a note to the table.
Refer to Item 5.f of Part I to Form 20-F.
Consolidated Financial Statements
Note 2.19. Revenue recognition, page F-26
4.You disclose that you do not charge transaction facilitation services fees to car dealers for
certain transactions without financing solutions attached.  Please address the following:
•Disclosure on page 87 indicates that you charge a fee for each car sold through your
2C business.  Please reconcile this apparent inconsistency.
•Clarify your disclosure to clearly state whether you provide transaction facilitation
services and warranties for transactions completed through your platform that are not
charged a fee.  Clarify how you account for such services provided in these
transactions.
•Tell us how you consider these transactions when allocating revenue to your
performance obligations in arrangements where you do charge a fee.
Refer to ASC 606-10-32-28.
Note 6. Loan Recognized as a Result of Payment Under the Guarantee, page F-39
5.Please revise future filings to reflect any additional required provision for existing loans,
any adjustments due to settlements from the Borrowers or other recoveries and any
adjustments due to the guarantees being bought out separately in the disclosure of the
activity in the allowance for loan losses.  Refer to ASC 310-10-50-11A(b)
6.Please revise future filings to present the balance of loans recognized as a result of
payment under the guarantee by monitored credit quality indicator.  Refer to ASC 310-10-
50-29.

 FirstName LastNameKun Dai
 Comapany NameUxin Limited
 July 18, 2019 Page 3
 FirstName LastName
Kun Dai
Uxin Limited
July 18, 2019
Page 3
            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 Rebekah Lindsey, Staff Accountant at (202) 551-3303 or Craig Wilson,
Senior Assistant Chief Accountant at (202) 551-3226 if you have any questions.
Sincerely,
Division of Corporation Finance
Office of Information Technologies
and Services