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 April 3, 2025

Christopher Britt
Chief Executive Officer
Chime Financial, Inc.
101 California Street, Suite 500
San Francisco, CA 94111

 Re: Chime Financial, Inc.
 Amendment No. 4 to Draft Registration Statement on Form S-1
 Submitted March 28, 2025
 CIK No. 0001795586
Dear Christopher Britt:

 We have reviewed your amended draft registration statement and have the
following
comments.

 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 a 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 letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our March 24, 2025 letter.

Amendment No. 4 to Draft Registration Statement on Form S-1
General

1. It appears that your two co-founders will control the company after the
initial public
 offering. Please clarify if you will be deemed a controlled company
under the listing
 standard and, if so, identify any exemptions you plan to take advantage
of.
2. We note the testimonials, for example beginning on page 130. Please tell
us how you
 identified the individuals you are highlighting in the testimonials.
Consider revised
 disclosure as necessary to ensure the presentation is balanced and
accurately places
 the information in context.
 April 3, 2025
Page 2

Glossary of Terms, page ii

3. We note the addition of three new products, Chime+, Instant Loans, and
Chime
 Workforce. Please revise or advise us why the glossary does not include
a short
 description of these products, similar to the description of your other
products.
Prospectus Summary, page 1

4. We note the reference to the co-founders "individually or together"
being able to
 determine or significantly influence any action requiring the approval
of your
 stockholders. Please revise here and where appropriate to clarify how
the relevant
 documents and parties would resolve potential conflicts in the event
there are
 disagreements between the co-founders.
Chime Workplace, page 161

5. We note your discussion of the new product, entitled Chime Workplace.
Please
 provide additional details about this product, specifically to clarify
the benefits and
 material risks, and to explain what you mean by your statement that it
is a "platform
 that was created to simplify benefits administration while boosting
employee
 participation and provide aggregated and measurable insights into the
financial health
 of their employees." Currently it is difficult to understand what is
meant by "an
 employee financial wellness solution."
Business
Bank Partnerships, page 208

6. We note your response to prior comment 8. We also note media articles
presenting
 available APY based on certain features, including 2% for standard users
who do not
 choose direct deposit. We also note your website refers to a "3.75% APY
on a high-
 yield savings account." Please revise or advise why these rates, or
ranges of recent
 rates made available to your members, are not material.
Description of Capital Stock, page 222

7. Please disclose the percentage of outstanding Class B shares your
co-founders must
 keep to continue to control the outcome of matters submitted to
shareholders for
 approval.
8. Please revise Conversion of Class B Common Stock and where appropriate
to explain
 the conversion features and the goal of these provisions in plain
English. Currently the
 legalese, defined terms such as Triggering Founder, and embedded
lists make the
 information difficult to understand. Please clarify the sunset
provisions that limit the
 lifespan of the high-vote class B shares. Also with respect to the
high-vote Class B
 shares, please revise the risk factor on page 59 or where appropriate to
describe the
 dilution and related risks to investors in the event of any future
issuances of high-vote
 Class B shares.
 April 3, 2025
Page 3

 Please contact Michael Henderson at 202-551-3364 or John Spitz at
202-551-3484 if
you have questions regarding comments on the financial statements and related
matters. Please contact Tonya Aldave at 202-551-3601 or James Lopez at
202-551-3536 with
any other questions.

 Sincerely,

 Division of Corporation
Finance
 Office of Finance
cc: Rezwan Pavri, Esq.
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