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June 24, 2024
Huen Ling Claire Luk
Chief Executive Officer
Roma Green Finance Ltd
Flat 605, 6/F., Tai Tung Building
8 Fleming Road, Wanchai, Hong Kong
Re:Roma Green Finance Ltd
Registration Statement on Form F-1
Filed June 7, 2024
File No. 333-280070
Dear Huen Ling Claire Luk:
            We have conducted a limited review of your registration statement and have the
following comment(s).
            Please respond to this letter by amending your registration statement and providing the
requested information. 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 any amendment to your registration statement and the information you
provide in response to this letter, we may have additional comments.
Registration Statement on Form F-1 filed June 7, 2024
Cover Page
1.We note that you have omitted certain disclosure from your prospectus cover page that
was provided in your Registration Statement on Form F-1, File No. 333-272555, in
response to the guidance in the Sample Letters to China-Based Companies. For example,
prominent disclosure regarding the legal and operational risks of operating in Hong Kong
and a discussion of the Holding Foreign Companies Accountable Act, as amended by the
Consolidated Appropriations Act, 2023, has been removed. We note that you still
maintain operations in Hong Kong, and it is unclear to us that there have been changes in
the regulatory environment in the PRC and/or Hong Kong warranting the elimination of
this disclosure. Therefore, please restore on the prospectus cover page all of the disclosure
responsive to the Sample Letters to China-Based Companies, updated as appropriate, that
was provided on the prospectus cover page in the above-referenced registration statement.

 FirstName LastNameHuen Ling Claire Luk
 Comapany NameRoma Green Finance Ltd
 June 24, 2024 Page 2
 FirstName LastName
Huen Ling Claire Luk
Roma Green Finance Ltd
June 24, 2024
Page 2
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Rebekah Reed at 202-551-5332 or Lilyanna Peyser at 202-551-3222 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services
cc:       David Stefanski