SEC Comment Letter 0000000000-23-011695 to Qfin Holdings, Inc. (QFIN)
Qfin Holdings, Inc.
Date: Oct. 25, 2023 · CIK: 0001741530 · Accession: 0000000000-23-011695
AI Filing Summary & Sentiment
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File numbers found in text: 001-38752
Letter
United States securities and exchange commission logo October 25, 2023 Alex Xu Chief Financial Officer Qifu Technology, Inc. 7/F Lujiazui Finance Plaza No. 1217 Dongfang Road Pudong New Area , Shanghai 200122 People’s Republic of China Re:Qifu Technology, Inc. Form 20-F for the Year Ended 2022 Filed April 27, 2023 File No. 001-38752 Dear Alex Xu: We have reviewed your September 28, 2023 response to our comment letter and have the following comment. Please respond to this letter 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 a comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to this letter, we may have additional comments. Unless we note otherwise, any references to prior comments are to comments in our September 18, 2023 letter. Form 20-F for the Year Ended 2022 Introduction, page 1 1.We note your response to prior comment 1 and reissue in part. In future filings, please also disclose in the definition section that the same legal and operational risks associated with operations in China may also apply to operations in Hong Kong. Please confirm your understanding and include your proposed disclosure in your response letter.
FirstName LastNameAlex Xu Comapany NameQifu Technology, Inc. October 25, 2023 Page 2 FirstName LastName Alex Xu Qifu Technology, Inc. October 25, 2023 Page 2
Please contact Michael Henderson at 202-551-3364 or Lory Empie at 202-551-3714 if you have questions regarding comments on the financial statements and related matters. Please contact John Stickel at 202-551-3324 or Susan Block at 202-551-3210 with any other questions. Sincerely, Division of Corporation Finance Office of Finance
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United States securities and exchange commission logo
October 25, 2023
Alex Xu
Chief Financial Officer
Qifu Technology, Inc.
7/F Lujiazui Finance Plaza
No. 1217 Dongfang Road
Pudong New Area , Shanghai 200122
People’s Republic of China
Re:Qifu Technology, Inc.
Form 20-F for the Year Ended 2022
Filed April 27, 2023
File No. 001-38752
Dear Alex Xu:
We have reviewed your September 28, 2023 response to our comment letter and have the
following comment.
Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our September 18, 2023
letter.
Form 20-F for the Year Ended 2022
Introduction, page 1
1.We note your response to prior comment 1 and reissue in part. In future filings, please
also disclose in the definition section that the same legal and operational risks associated
with operations in China may also apply to operations in Hong Kong. Please confirm your
understanding and include your proposed disclosure in your response letter.
FirstName LastNameAlex Xu
Comapany NameQifu Technology, Inc.
October 25, 2023 Page 2
FirstName LastName
Alex Xu
Qifu Technology, Inc.
October 25, 2023
Page 2
Please contact Michael Henderson at 202-551-3364 or Lory Empie at 202-551-3714 if
you have questions regarding comments on the financial statements and related matters. Please
contact John Stickel at 202-551-3324 or Susan Block at 202-551-3210 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Finance