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October 3, 2023
Ting Kin Cheung
Chief Executive Officer
Plutus Financial Group Limited
8/F, 80 Gloucester Road
Wan Chai, Hong Kong
Re:Plutus Financial Group Limited
Amendment No. 6 to
Draft Registration Statement on Form F-1
Submitted September 15, 2023
CIK No. 0001933021
Dear Ting Kin Cheung:
            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.
Amendment No. 6 to Draft Registration Statement on Form F-1
Cover Page
1.Please revise your cover page and make corresponding changes elsewhere in the
prospectus to disclose a fixed price at which the selling stockholders will offer and sell
shares until your shares are listed on a national securities exchange or quoted on the
OTCQX or OTCQB at which time they may be sold at prevailing market prices.  Refer to
Item 501(b)(3) of Regulation S-K.  In addition, please clarify whether the primary offering
is conditioned upon receiving approval to list your Ordinary Shares on the Nasdaq Capital
Market.  In this regard, we note your disclosure that "[t]here is no assurance . . . that the
Ordinary Shares of Plutus Group will be trading on Nasdaq Capital Market."
2.Refer to your response to comment 2.  Your revised disclosure on your cover page, in

 FirstName LastNameTing Kin Cheung
 Comapany NamePlutus Financial Group Limited
 October 3, 2023 Page 2
 FirstName LastNameTing Kin Cheung
Plutus Financial Group Limited
October 3, 2023
Page 2
your prospectus summary and in your risk factors section specifically highlights the
impact to your business if you cannot transfer cash out of Hong Kong but does not
similarly highlight the impact if you cannot transfer cash into Hong Kong.  Please revise
to state here, in your prospectus summary and in your risk factors section that there is no
assurance that the PRC government will not intervene or impose restrictions on your
ability to transfer cash into China, including Hong Kong, and include a discussion
regarding the impact if you cannot transfer cash into Hong Kong.  In this regard, we note
that on your cover page and in your prospectus summary you include a cross reference to
your risk factor that states "[t]here is no assurance that the PRC government will not
intervene or impose restrictions on [y]our ability to transfer cash into or out of Hong
Kong."  Please include this risk in your Summary of Significant Risk Factors section
along with a cross-reference to the risk factor in your risk factors section.
Margin Financing, page 4
3.We note your response to bullet point four in comment 3. Your disclosure on page 5
indicates there are no financing or other related costs for the margin lending business;
however, the disclosures on page 26 indicate that the Company derives the funding for its
margin financing business from a variety of sources, including funding secured from
commercial banks, other licensed financial institutions and other parties as well as
financing generated from our business operations. The latter suggests that there may, in
fact, be financing or other costs related to margin lending. Please revise to address or
clarify this inconsistency.
Selling Stockholders, page 48
4.Please revise your table on page 48 to show the percentage owned by each selling
stockholder prior to the completion of the offering.
Analysis of Items with Major Changes on the Consolidated Balance Sheets
Balances with related parties, page 72
5.Please revise your disclosures to provide a more detailed and thorough discussion of your
relationship with Fund SPC and its subsidiaries.  Your revisions should address the
following:
•Define and explain what you mean when you say that Plutus Asset Management
“holds management shares”.
•Discuss what services are provided by the Fund SPC and its subsidiary entities, and
how related revenue, expenses, receivable and payable amounts are determined.
•Disclose payment terms for the SPC-related receivables and payables.
•Explain whether you are required to fund the operating expenses of the Fund SPC
and / or its subsidiaries. If so, explain why this is the case; if not, explain why you
have settled such expenses on behalf of them to date.
•Address how you plan to pay amounts owed to Fund SPC and its subsidiaries
(HK$20,038,000), given the liquidity levels of the Company at December 31, 2022.

 FirstName LastNameTing Kin Cheung
 Comapany NamePlutus Financial Group Limited
 October 3, 2023 Page 3
 FirstName LastName
Ting Kin Cheung
Plutus Financial Group Limited
October 3, 2023
Page 3
Related Party Transactions, page 113
6.Refer to your response to comment 14.  Your disclosure on page 114 that "[t]he amount
due from Mr. Zhao was mainly resulted from the financial support provided to the
Company by Mr. Zhao" seems to contradict your disclosure that these are amounts due
from Mr. Zhao.  Please revise to clarify this disclosure so that it is clear that these are
amounts due from Mr. Zhao.  In addition, please revise to clarify as to whether these
amounts will be paid to you prior to the effectiveness of your registration statement.
            Please contact Marc Thomas at 202-551-3452 or Cara Lubit at 202-551-5909 if you have
questions regarding comments on the financial statements and related matters. Please contact
Sonia Bednarowski at 202-551-3666 or Jessica Livingston at 202-551-3448 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:       Joe Laxague, Esq.