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Correspondence 0001104659-24-077958 from ONECONNECT FINANCIAL TECHNOLOGY CO., LTD. (OCFT) (CIK 0001780531)

ONECONNECT FINANCIAL TECHNOLOGY CO., LTD. (OCFT) (CIK 0001780531)
Date: July 5, 2024 · CIK: 0001780531 · Accession: 0001104659-24-077958

AI Filing Summary & Sentiment

File numbers found in text: 001-39147

Referenced dates: June 24, 2024

Date
December 31, 2023
Author
/s/ Yongtao Luo
Form
CORRESP
Company
ONECONNECT FINANCIAL TECHNOLOGY CO., LTD. (OCFT) (CIK 0001780531)

Letter

VIA EDGAR Division of Corporation Finance Office of Technology Washington, D.C. 20549 Re: OneConnect Financial Technology Co., Ltd. (the “Company”) Form 20-F for the year ended December 31, 2023 (“FY 2023 20-F”) File No. 001-39147

Dear Ms. Ebbertt and Ms. Collins:

In response to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated June 24, 2024 (the “Comment Letter”), the Company submits this letter containing its responses to the Comment Letter via EDGAR to the Commission.

For your convenience, the Staff’s comments from the Comment Letter are repeated below in bold, followed by the Company’s responses. Capitalized terms used but not otherwise defined herein have the meanings set forth in FY 2023 20-F. Simultaneously with the transmission of this letter, the Company is filing via EDGAR amendment No. 1 to FY 2023 20-F (the “Amendment”), responding to the Staff’s comment.

Form 20-F for the year ended December 31,

General

1. Please amend your Form 20-F to revise the certifications filed as Exhibit 12.1 and 12.2 to refer to the certifying officers’ responsibility for establishing and maintaining both disclosure controls and procedures and internal control over financial reporting, as defined in Exchange Act Rules 13a-14(a) or 15d-14(a).

In response to the Staff’s comment, the Company has revised Exhibits 12.1 and 12.2 (together, “Exhibits”) to refer to the certifying officers’ responsibility for establishing and maintaining both disclosure controls and procedures and internal control over financial reporting, as defined in Exchange Act Rules 13a-14(a) or 15d-14(a). Such Exhibits are filed as exhibits to the Amendment.

If you have any questions regarding the FY 2023 20-F, please contact Mr. Yongtao Luo, the Chief Financial Officer of OneConnect Financial Technology Co., Ltd., by telephone at (86) 21 38638706 or via e-mail at LUOYONGTAO001@ocft.com.

Very truly yours,
By:
/s/ Yongtao Luo

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CORRESP
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OneConnect Financial Technology Co., Ltd.

21/24F, Ping An Finance Center, No. 5033
Yitian Road

Futian District, Shenzhen, Guangdong, 518000

The People’s Republic of China

July 5,
2024

VIA EDGAR

Brittany Ebbertt

Kathleen Collins

Division of Corporation Finance

Office of Technology

U.S. Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re: OneConnect Financial Technology
Co., Ltd. (the “Company”)

Form 20-F for the year ended December 31, 2023
(“FY 2023 20-F”)

File No. 001-39147

Dear
Ms. Ebbertt and Ms. Collins:

In response to the comments
of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) dated June 24, 2024
(the “Comment Letter”), the Company submits this letter containing its responses to the Comment Letter via EDGAR to the Commission.

For your convenience, the
Staff’s comments from the Comment Letter are repeated below in bold, followed by the Company’s responses. Capitalized terms
used but not otherwise defined herein have the meanings set forth in FY 2023 20-F. Simultaneously with the transmission of this letter,
the Company is filing via EDGAR amendment No. 1 to FY 2023 20-F (the “Amendment”), responding to the Staff’s comment.

Form 20-F for the year ended December 31,
2023

General

 1. Please amend your Form 20-F to revise the certifications filed as Exhibit 12.1 and 12.2 to refer to the certifying officers’
responsibility for establishing and maintaining both disclosure controls and procedures and internal control over financial reporting,
as defined in Exchange Act Rules 13a-14(a) or 15d-14(a).

In response to the Staff’s
comment, the Company has revised Exhibits 12.1 and 12.2 (together, “Exhibits”) to refer to the certifying officers’
responsibility for establishing and maintaining both disclosure controls and procedures and internal control over financial reporting,
as defined in Exchange Act Rules 13a-14(a) or 15d-14(a). Such Exhibits are filed as exhibits to the Amendment.

If
you have any questions regarding the FY 2023 20-F, please contact Mr. Yongtao Luo, the Chief Financial Officer of OneConnect Financial
Technology Co., Ltd., by telephone at (86) 21 38638706 or via e-mail at LUOYONGTAO001@ocft.com.

    Very truly yours,

    By:
     /s/ Yongtao Luo

    Name: Yongtao Luo

    Title: Chief Financial Officer

cc: Ms. Shuang Zhao, Partner, Cleary Gottlieb Steen &
Hamilton LLP