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September 20, 2024

VIA EDGAR

Division of Corporation Finance

Office of Crypto Assets

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention: Michelle Miller

  Mark Brunhofer

Re: Futu Holdings Limited

  Form 20-F for the Fiscal Year Ended December 31,
2023

  Filed April 24, 2024

  File No. 001-38820

Dear Ms. Miller and Mr. Brunhofer:

We, Futu Holdings Limited (the “Company”),
are responding to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
contained in the letter dated August 22, 2024 (the “Comment Letter”), relating to the above-captioned Form 20-F
(the “2023 Form 20-F”). All capitalized terms used but not defined in this letter shall have the meaning
ascribed to such terms in the 2023 Form 20-F.

For the Staff’s convenience, the comments
in the Comment Letter are reproduced and repeated below in bold, with the Company’s response set forth in regular font immediately
thereafter. The Company respectfully advises the Staff that where the Company proposes to add or revise disclosure to its future filings
on Form 20-F in response to the Staff’s comments, the changes to be made will be subject to relevant factual updates and changes
in relevant laws or regulations, or in interpretations thereof.

Form 20-F for the Fiscal Year Ended
December 31, 2023

Item 4. Information on the Company

B. Business Overview, page 84

 1. We note your use of and definition that “paying clients” are “clients with assets
in their trading accounts with you”. With a view towards enhancing your disclosures in future filings, tell us how client account
assets always result in payments to you. Excluding products and services disclosed on pages 89 through 94 that appear to have separate
and distinct performance obligations aside from the existence of account assets, it is unclear how clients with assets would always be
paying clients.

In response to the Staff’s comment,
the Company respectfully advises the Staff that it will revise the term from the “paying clients” to the “funded accounts”
in its future Form 20-F filings.

Futu
Holdings Limited 34/F, United Centre, 95 Queensway, Admiralty, Hong Kong S.A.R., People’s Republic of China

t: +852 2523 3588 futuholdings.com

U.S. Securities and Exchange Commission

 Page 2

Item 5. Operating and Financial Review and Prospects

Key Components of Results of Operations

Revenues

Brokerage commission and handling charge income, page 175

 2. We note your disclosures on pages 82 through 89, and 175, including that you generate commissions
and execution fees on securities brokerage by trading equities and equity-linked derivatives, the various securities dealer licenses you
hold, and that you provide trade execution services for stocks, ETFs, warrants, options and futures, across different markets. Considering
also your growth, both organically and by acquisition, for the periods presented, represent to us that in future filings you will disclose
the following:

 · Disaggregate total brokerage commissions and handling charge income by product, i.e. equities, equity-linked
derivatives by type and provide explanations for period over period changes;

 · Disaggregate total brokerage commissions and handling charge income by geography and provide explanations
for period over period changes; and

 · Disaggregate total trading volume by product and provide explanations for period over period changes.

Refer to Item 303(b)(2) of Regulation
S-K. Otherwise, tell us why these disclosures are not warranted.

In response to the Staff’s comment
on the disaggregation of total brokerage commissions and handling charge income by product and geography, the Company proposes to revise
the disclosure in “Item 5. Operating and Financial Review and Prospects — A. Operating Results — Key Components of Results
of Operations — Revenues” in its future Form 20-F filings as follows (with changes marked in italics, additions underlined
and the relevant disclosures to be updated as necessary):

“Brokerage
commission and handling charge income

Brokerage commission income primarily
consists of commissions and execution fees from our clients for whom we act as executing and clearing brokers. We generate commissions
and execution fees on securities brokerage by trading equities and equity-linked derivatives on behalf of our clients. Handling charge
income primarily consists of fees from clearing and settlement services as well as subscription and dividend collection handling services.

U.S. Securities and Exchange Commission

 Page 3

The table below sets forth the
brokerage commissions and handling charge income by product and geography during the period presented:

    Year
    ended December 31,

    2021

    2022

    2023

    (HK$
    in thousands)

    Major types of products

    Securities and options brokerage(1)

    3,688,149

    3,619,045

    3,618,681

    Futures brokerage(2)

    130,775

    329,218

    295,547

    IPO brokerage(3)

    75,571

    21,123

    12,364

    Others(4)

    18,532

    38,256

    18,187

    Total

    3,913,027

    4,007,642

    3,944,779

    Geographic location(5)

    Hong Kong(6)

    3,804,194

    3,514,765

    3,197,605

    Others(7)

    108,833

    492,877

    747,174

    3,913,027

    4,007,642

    3,944,779

 (1) The brokerage commissions and handling charge income from securities and options brokerage declined
by 1.9% from HK$3,688.1 million in 2021 to HK$3,619.0 million in 2022, and further to HK$3,618.7 million in 2023, which was mainly due
to lower trading volume, largely offset by the higher blended commission rates. Total trading volume for securities and options decreased
from HK$6.13 trillion in 2021 to HK$4.85 trillion in 2022, and further to HK$4.23 trillion in 2023, primarily due to weak market sentiments.
The blended commission rate increased from 6.4bps in 2021 to 8.3 bps in 2022, and further to 9.3 bps in 2023.

 (2) The brokerage commissions and handling charge income from futures brokerage increased from HK$130.8
million in 2021 to HK$329.2 million in 2022, and declined to HK$295.5 million in 2023, which was generally in line with the fluctuation
of the number of contracts traded for futures brokerage. The number of contracts traded for futures brokerage increased from 9.3 million
in 2021 to 20.7 million in 2022, and decreased to 19.1 million in 2023.

 (3) The brokerage commissions and handling charge income from IPO brokerage declined from HK$75.6million
in 2021 to HK$21.1 million in 2022, and further to HK$12.4 million in 2023, which was primarily due to a downturn in the IPO market and
a decrease in the overall number of IPO transactions in the U.S. and Hong Kong markets.

 (4) Others include (i) handling fees, such as dividend collection fees, equity interest collection
fees, corporate action handling fees, (ii) bond brokerage commission, and (iii) service fees, such as ESOP handling charges.

 (5) Based on the place of incorporation of the subsidiaries in which the revenues are recorded.

 (6) The brokerage commissions and handling charge income in Hong Kong declined by 7.6% from HK$3,804.2
million in 2021 to HK$3,514.8 million in 2022, and further declined by 9.0% to HK$3,197.6 million in 2023, which was mainly due to lower
trading volume in line with the weak market sentiments.

 (7) The brokerage commissions and handling
charge income in other geographic locations increased from HK$108.8 million in 2021 to HK$492.9 million in 2022, and further to HK$747.2
million in 2023, which
was mainly related to increased number of funded accounts in our new markets, driven by our growing market share and the enrichment of
our product and service offerings in these markets.”

In addition, in response to the Staff’s
comment on the disaggregation of total trading volume by product, the Company proposes to revise the disclosure in “Item 5. Operating
and Financial Review and Prospects — A. Operating Results — Key Factors Affecting Our Results of Operations” in its
future Form 20-F filings as follows (with changes marked in italics, deletions as strike-through, additions underlined and the relevant
disclosures to be updated as necessary). The Company respectfully advises the Staff that the concept of trading volume does not apply
to its IPO brokerage and other products. Revenue from IPO brokerage is derived from IPO subscription services, which are charged based
on a fixed fee rather than trading volume. Similarly, revenue from others, such as dividend collection fees, corporate action handling
fees, and ESOP handling charges, is also independent of trading volume.

U.S. Securities and Exchange Commission

Page 4

“Trading
activities of our client and commission rate

Growth in the trading volume on our
platform is the key driver of our revenue growth, which is in turn driven by total client asset balance and turnover of trading volume
over client assets. The change of the trading volume was primarily driven by market sentiment and our total client asset balance, the
latter of which significantly impacted our brokerage commission and handling charge income and interest income during the past few years.
Our total client asset balance is affected by a number of factors, including, primarily, the number of our paying clients funded
accounts and to a lesser extent, the level of per capita disposable income as well as the engagement and loyalty of our clients.
The trading volume on our platform declined year-over-year in 2023 compared to 2022, primarily due to weak performance of global capital
market and declining investor sentiment. We plan to continue to grow our business organically by attracting new clients, retaining existing
clients and increasing our total client asset balance, and to introduce new products and services on our platform and provide high-quality,
reliable and convenient online brokerage and ancillary services to investors at low costs.

The table below sets forth the
trading volume by product during the period presented:

    Year
    ended December 31,

    2021
    2022
    2023

    Trading volume

    Securities and options brokerage (HK$ in trillion)(1)
      6.13
      4.85
      4.23

    Futures brokerage (number of contracts in million)(2)
      9.3
      20.7
      19.1

 (1) Total trading volume for securities and options decreased from HK$6.13 trillion in 2021 to HK$4.85
trillion in 2022, and further to HK$4.23 trillion in 2023, primarily due to weak market sentiments.

 (2) The number of contracts traded for futures
brokerage increased from 9.3 million in 2021 to 20.7 million in 2022, and decreased to 19.1 million in 2023. The increase in the number
of contracts traded for futures in 2022 was generally in line with the expansion of our futures trading services and the increasing need
of our clients to use such services. The decrease in the number of contracts traded for futures in 2023 was in line with futures market
sentiments”

In
addition to trading volume, our brokerage commission and handling charge income is also affected by the commission rate we charge. The
brokerage commissions and handling charge income from securities and options brokerage declined by 1.9% from HK$3,688.1 million in 2021
to HK$3,619.0 million in 2022, and further to HK$3,618.7 million in 2023, mainly due to lower trading volume that was largely offset by
the higher blended commission rates. The blended commission rate increased from 6.4bps in 2021 to 8.3 bps in 2022, and further to 9.3
bps in 2023. During the past three years, we offered competitive commission rates to drive our growth and profitability.”

U.S. Securities and Exchange Commission

Page 5

Interest Income, page 175

 3. We note that interest income was 55% of total revenue in 2023, increasing from 42% in 2022 and 35%
in 2021. We also note that while bank deposits and securities lending were the main drivers of the increase in interest income, margin
financing was 18% of total revenues in 2023, 21% in 2022 and 24% in 2021. Considering the significance of interest income to total revenues,
as well as the change in drivers of total interest income for the periods presented, please represent to us that you will enhance your
disclosures in future filings to provide a yield analysis that addresses the following:

 · Disaggregates interest income, based on the underlying interest earning assets, i.e. bank deposit,
margin financing, securities lending, etc. as presented in Note 19 to your financial statements on page F-47;

 · Presents for each category of interest earning assets and in the aggregate, the average asset balance
outstanding for the periods presented and the annualized yield based on the related average interest earning balance;

 · Separately indicates the basis used to calculate the average asset balances; and

 · Discusses the drivers resulting in changes in yields for each category of interest earning assets period
over period.

Refer to Item 303(b)(2) of Regulation
S-K. Otherwise, tell us why these would not provide meaningful information to investors.

In response to the Staff's comment,
the Company proposes to revise the disclosure in “Item 5. Operating and Financial Review and Prospects — A. Operating Results
 — Key Components of Results of Operations — Revenues” in its future Form 20-F filings as follows (with changes
marked in italics, additions underlined and the relevant disclosures to be updated as necessary) to include the average asset balance
outstanding and the annualized yield of the major interest earning assets, including bank deposits and margin financing, for the relevant
period as follows:

“Interest
income

We earn interest income primarily from
margin financing and securities lending services, IPO financing, stock-pledged loan, treasury bills and deposits with banks, which
are recorded on an accrual basis and are included in interest income in the consolidated statements of comprehensive income. Interest
income is recognized as it is accrued over time using the effective interest method.

U.S. Securities and Exchange Commission

Page 6

The table below sets forth the
interest income based on the underlying interest earning assets during the period presented:

    Year
                                            ended December 31,

    2021
    2022
    2023

    (HK$ in thousands)

    Interest income from:

    Bank deposits
      197,390
      986,387
      2,482,866

    Margin financing
      1,720,473
      1,588,569
      1,754,056

    Securities lending
      397,505
      499,745
      1,053,294

    Stock-pledged loans
      1,872
      135,733
      170,566

    Treasury bills
      —
      —
      68,556

    IPO and other financing
      200,958
      3,893
      7,084

    Total
      2,518,198
      3,214,327
      5,536,422

The table below sets forth the
average asset balance outstanding and the annualized yield of our major interest earning assets during the period presented:

    Year
    ended December 31,

    2021
    2022
    2023

    (HK$ in thousands)

    Average
    interest-earning asset balance(1)

    Bank deposits
      62,814,766
      61,980,140
      55,260,272

    Margin financing
      29,190,981
      25,728,035
      29,313,160

    Annualized yields(2)

    Bank deposits(3)
      0.3 %
      1.6 %
      4.5 %

    Margin financing(4)
      5.9 %
      6.2 %
      6.0 %

 (1) Average interest-earning asset balance represents the simple average of month-end balances in a
given period.

 (2) Annual yield is calculated by dividing revenue for the given period by the applicable average asset
balance.

 (3) The increase in annualized yields of bank deposits was mainly attributable to the growing market
interest rates amid rates hikes.

 (4) The annualized yields of margin financing
remained relatively stable as a result of our fixed pricing structure for margin financi