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December 14, 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. 7 to
Draft Registration Statement on Form F-1
Submitted December 8, 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. 7 to Draft Registration Statement on Form F-1
Cover Page
1.We note your disclosure on the cover page that WWC, P.C. is not headquartered in
mainland China or Hong Kong.  Please revise to state where WWC, P.C. is
headquartered.  In addition, please revise to remove your disclosure that "[a]s of the date
of this prospectus, the Company is not subject to the PRC government’s direct influence
or discretion over the manner in which it conducts its business activities outside of the
PRC" and your disclosure that you do "not presently foresee material changes to
[your] operating subsidiaries’ operations or the value of the Company’s Ordinary Shares
resulting from the legal and operational risks relating to the PRC regulations" to clarify
the PRC's government's significant oversight and direction over the conduct and
operations of your business.  In this regard, we remind you that, pursuant to the federal

 FirstName LastNameTing Kin Cheung
 Comapany NamePlutus Financial Group Limited
 December 14, 2023 Page 2
 FirstName LastNameTing Kin Cheung
Plutus Financial Group Limited
December 14, 2023
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securities rules, the term" control“ (including the terms "controlling," "controlled by," and
"under common control with") means “the possession, direct or indirect, of the power to
direct or cause the direction of the management and policies of a person, whether through
the ownership of voting securities, by contract, or otherwise.”  In addition, please revise to
clarify here as to whether you are required to obtain CSRC approval for this offering
pursuant to the Trial Measures and disclose the impact to your company if you are
required to obtain such approval but do not.
Prospectus Summary
Transfer of Cash To and From Our Subsidiaries, page 14
2.Refer to your response to comment 2.  Please revise your disclosure in this section to state
that there is no assurance that the PRC government will not intervene or impose
restrictions on your ability to transfer cash into or out of Hong Kong.
Use of Proceeds, page 51
3.We note your disclosure that a portion of offering proceeds will be used for credit line
trading.  Please revise your disclosure, here or elsewhere, to define and explain “credit
line trading” to explain where it fits into and corresponds with your current business
line(s).  If it is a different or new business, expand your disclosure to fully describe this
business.
4.Please revise your disclosures to define “non-accountable expense allowance,” explain
what it represents, and address the reason(s) for allocating an estimated 1% of offering
proceeds to it.
Mangement's Discussion and Analysis of Financial Condition and Results of Operations, page 58
5.Please revise your disclosures to include a discussion of operating results and financial
position for the six-month periods ended June 30, 2022 and June 30, 2023.  Also include a
discussion of liquidity and capital resources.  Refer to Item 4 of Form F-1, Part I.
Segment Performance for fiscal year ended December 31, 2021 and 2022
Revenues, page 66
6.Please revise to disclose the related party revenues generated from Fund SPC for the
provision of asset management services for each of the periods presented.
Related Party Transactions
Amounts due from related parties, page 114
7.Refer to your response to comment 6.  Please revise to clarify, if true, that Mr. Zhao, Mr.
Cheung and any of your officers and directors that have outstanding loans with you will
pay you the amounts due prior to the effectiveness of the registration statement, and please
update your registration statement when such amounts have been paid.

 FirstName LastNameTing Kin Cheung
 Comapany NamePlutus Financial Group Limited
 December 14, 2023 Page 3
 FirstName LastName
Ting Kin Cheung
Plutus Financial Group Limited
December 14, 2023
Page 3
            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.