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UPLOAD Filing

Qfin Holdings, Inc.
Date: Aug. 5, 2025 · CIK: 0001741530 · Accession: 0000000000-25-008226

Risk Disclosure Regulatory Compliance Financial Reporting

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File numbers found in text: 001-38752

Date
August 5, 2025
Author
Division of
Form
UPLOAD
Company
Qfin Holdings, Inc.

Letter

Re: Qfin Holdings, Inc. Form 20-F for the year ended December 31, 2024 Response dated July 31, 2025 File No. 001-38752 Dear Alex Xu:

August 5, 2025

Alex Xu Chief Financial Officer Qfin Holdings, Inc. 7/F Luijazui Finance Plaza, No. 1217 Dongfang Road Pudong New Area, Shanghai 2000122 PRC

We have reviewed your July 31, 2025 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 July 17, 2025 letter.

Form 20-F for the year ended December 31, 2024 Risk Factors Changes in China's economic, political or social conditions or government policies could have a material adverse effect..., page 54

1. We note your response to prior comment 1, including where you propose to disclose that The regulatory environment in China is subject to change, and companies operating in China, including ours, may be affected by evolving government policies and regulations. As a result, investors of our Company may face uncertainties related to the regularly landscape and economic policies in China. The Chinese government also directs China s economic growth The proposed revisions do not fully restore your disclosure to the disclosure as contained in the Form 20-F filed April 27, 2023. As previously requested, please revise to instead disclose that the PRC government has significant authority to exert influence on the ability of a China-based company to August 5, 2025 Page 2

conduct its business, that investors face potential uncertainty from the PRC government, and that the Chinese government exercises significant control over the Chinese economy, as you previously disclosed in the Form 20-F filed April 27, 2023. Please contact Brittany Ebbertt at 202-551-3572 or Kathleen Collins at 202-551-3499 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of
Corporation Finance
Office of Technology
cc: Haiping Li

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 August 5, 2025

Alex Xu
Chief Financial Officer
Qfin Holdings, Inc.
7/F Luijazui Finance Plaza, No. 1217 Dongfang Road
Pudong New Area, Shanghai 2000122 PRC

 Re: Qfin Holdings, Inc.
 Form 20-F for the year ended December 31, 2024
 Response dated July 31, 2025
 File No. 001-38752
Dear Alex Xu:

 We have reviewed your July 31, 2025 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 July 17,
2025 letter.

Form 20-F for the year ended December 31, 2024
Risk Factors
Changes in China's economic, political or social conditions or government
policies could
have a material adverse effect..., page 54

1. We note your response to prior comment 1, including where you propose to
disclose
 that The regulatory environment in China is subject to change, and
companies
 operating in China, including ours, may be affected by evolving
government policies
 and regulations. As a result, investors of our Company may face
uncertainties related
 to the regularly landscape and economic policies in China. The Chinese
government
 also directs China s economic growth The proposed revisions do
not fully restore
 your disclosure to the disclosure as contained in the Form 20-F filed
April 27, 2023.
 As previously requested, please revise to instead disclose that the PRC
government
 has significant authority to exert influence on the ability of a
China-based company to
 August 5, 2025
Page 2

 conduct its business, that investors face potential uncertainty from the
PRC
 government, and that the Chinese government exercises significant
control over the
 Chinese economy, as you previously disclosed in the Form 20-F filed
April 27, 2023.
 Please contact Brittany Ebbertt at 202-551-3572 or Kathleen Collins at
202-551-3499
if you have questions regarding comments on the financial statements and
related matters.

 Sincerely,

 Division of
Corporation Finance
 Office of Technology
cc: Haiping Li
</TEXT>
</DOCUMENT>