SecProbe.io

May 22, 2019
Xiao Chen
Chief Financial Officer
Prestige Wealth Inc.
Suite 5102, 51/F
Cheung Kong Center
2 Queen’s Road Central
Hong Kong
Re:Prestige Wealth Inc.
Amendment No. 2 to
Draft Registration Statement on Form F-1
Submitted May 10, 2019
CIK No. 0001765850
Dear Ms. Chen:
            We have reviewed your amended draft registration statement and have the following
comment.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR.  If you do not believe our comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this comment and your
amended draft registration statement or filed registration statement, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
April 24, 2019 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1
Prospectus Summary
Overview
Our Wealth Management Services, page 1
1.We note your revisions in response to comment 2.  Please further revise here and on page
59 to disclose the material features of the savings plans that you facilitate given that the
referral fees from the sale of savings plans were the basis for substantially all of your
revenues in your most recently completed fiscal year.  For example, in order for investors

 FirstName LastNameXiao Chen
 Comapany NamePrestige Wealth Inc.
 May 22, 2019 Page 2
 FirstName LastName
Xiao Chen
Prestige Wealth Inc.
May 22, 2019
Page 2
to understand a policy holder's "guaranteed cash value" of such plans, please quantify the
ranges of the "minimum guaranteed compound interest rate[s]" as well as "the cost of the
actual insurance policy," clarifying whether interest accumulates on a policy's cost or on
some other amount.  Please also disclose the material features of how a savings plan's
"non-guaranteed bonus" is calculated by outlining which funds are invested, the type of
eligible investments and or markets where investments are made, and identify the party
retaining investment authority.  Please also revise to explain how the "non-guaranteed
bonus" differs from these underlying "investment returns" and specify how "market
volatility" impacts the non-guaranteed bonus.  Finally, please revise throughout your
prospectus to disclose, if true, that savings plans are substantially similar to annuities or
explain the material differences between savings plans and annuities.
            You may contact William Schroeder, Staff Accountant, at (202) 551-3294 or Michael
Volley, Staff Accountant, at (202) 551-3437 if you have questions regarding comments on the
financial statements and related matters.  Please contact Christopher Dunham, Staff Attorney, at
(202) 551-3783 or Pamela A. Long, Assistant Director, at (202) 551-3765 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Financial Services
cc:       Ying Li, Esq.