SecProbe.io

September 30, 2024
Chan Wan Shan Sandra
Chief Executive Officer
Bluemount Holdings Limited
Room 1007, 10/F, Capital Centre
151 Gloucester Road
Wan Chai, Hong Kong
Re:Bluemount Holdings Limited
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted September 16, 2024
CIK No. 0002027815
Dear Chan Wan Shan Sandra:
            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
July 19, 2024 letter.
Amendment No. 1 to the Draft Registration Statement on Form F-1
General
We note your response to prior comment 1 and your revised disclosure in the summary
and business section. Please further revise as follows:
•in your overview section on page 1, please clarify what percentage of your revenues
was derived in recent fiscal years form your financial services segment and to put it in
perspective with two other business lines that contribute to more than 97% of your
revenues; and
•revise your business section starting on page 99, to clearly identify each of the three
business lines you appear to be engaged in; and1.

September 30, 2024
Page 2
•revise here to give prominence to business lines that are most material to your
business.
2.We note your response to prior comment 28 and reissue in part. You removed references
to online platform in some sections of the registration statement but continue to reference
platforms or online platforms in other sections, for example, refer to your disclosure on
pages 13, 28, and 113. Please explain the relevance of platforms or online platforms to
your business in the summary, business, and risk factors sections or remove all references
to platforms throughout the registration statement.
Overview, page 1
3.We note your response to prior comment 11 and reissue in part.  We also note your
revised disclosure that "[m]ost of the revenue [you] make comes from selling to one
important business partner, Customer A, who is a private company incorporated in Hong
Kong with limited liability" and that your partnership with Customer A "has been strong
since December 2021, helping [you] stay financially secure and showing that they will
probably keep buying from [you]." Because Customer A accounted for a significant
percentage of your revenue in fiscal year 2024, please identify Customer A on pages 1,
24, 69, and 83-84, disclose the terms of any material agreements with Customer A, and
file the agreements as exhibits.
Corporate History and Structure, page 4
4.Please refer to prior comment 9.  Please revise to clarify what the percentages below each
box represent in you corporate structure diagram.
Risk Factors, page 20
5.We note your response to prior comment 3 and that you have removed the definition of
the "controlling shareholders" from the registrations statement. We also note your
disclosure on page F-9 where you state that "[t]he Company, together with its wholly-
owned subsidiaries, is effectively controlled by the same controlling shareholders, i.e.,
ultimately held 27.45% by Mr. Pan, 26.08% by Mr. Yan, 16.47% by Ms. Zhou and
30.00% by Echo International Holdings Group Limited." If you will be controlled by a
small group of shareholders following the initial public offering, please revise throughout
to make that clear and add risk factor disclosure to advise the investors of the
various material risks arising with being a controlled company. In addition, tell us if there
are any voting arrangements or agreements among the above referenced shareholders.
Recent joint statement by the SEC and PCAOB, page 44
6.We note your response to prior comment 14 and your revised disclosure in this risk factor.
Please further revise here to state that the value of the securities you are registering for
sale can significantly decline or become worthless.
Impairment loss on trade and other receivables, page 74
Please refer to prior comment 21. Please revise to provide additional information to allow
an investor to better understand the specific facts about the relevant
receivables/customers and the underlying factors that resulted in the material amount of 7.

September 30, 2024
Page 3
credit impairment recognized in 2023. For example, discuss the number of
receivables/customers the impairment related to, any specific factor that triggered the
recognition related to any material individual amounts, whether you recognized
impairment related to the entire customer balances due or only a portion of balances due,
etc.
Industry, page 91
8.We note that you refer to various industry sources in this section. Please revise throughout
this section to address the following:
•refer to prior comment 27 and provide URL addresses for each source cited in
footnotes;
•refer to prior comment 24 and provide support for your disclosure in this section that
the "market size of the [consulting services] industry reach[ed] more than one trillion
U.S. dollars in 2022;" and
•tell us if any of the information cited is based on reports commissioned by you and
independently prepared for you in connection with this offering.  If so, refer to Rule
436 and provide consents for each of the reports commissioned by you.
Business
Financial Services Business Segment, page 100
9.We note your response to prior comment 31. Please revise this subsection significantly as
follows:
•provide additional details on the services you offer under the consulting and advisory
business segment;
•describe how you are compensated for each of the services described on pages 101-
102, such as commissions, flat fees or otherwise;
•revise disclosure starting on page 101 and through the end of page 102 to be placed
within consulting and advisory services segment or advise how the description of the
services listed here falls within "financial services;" and
•because you derive most of your revenues from business consulting and advisory
services, move the description of this business line to the beginning of the business
section.
External Brokers, page 113
10.We note your removal of the identity of your external broker for U.S. exchanges. Please
identify the external broker or advise.
Strengthening our placing and underwriting services, page 119
We note your response to prior comment 30 and your revised disclosure that with less
than 2% of your total revenue derived from placing and underwriting services, you
"maintain" that your "placing and underwriting business remain as [y]our core
competence since the management team believes that the Hong Kong capital market will
rebound as investor confidence returns, aided by potential market reforms and economic
recovery efforts." Please revise this sentence to state as belief of management or remove 11.

September 30, 2024
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this disclosure.
Principal Shareholders, page 151
12.We note your response to prior comment 35 and reissue in part.  Please disclose the
percentage of outstanding shares that holders of Class A ordinary shares must keep to
continue to control the outcome of matters submitted to shareholders for approval. It also
appears that a small group of shareholders will be able to control the company after the
initial public offering. If applicable, please explain the controlling shareholders' ability to
control matters requiring shareholder approval, including the election of directors,
amendments of organizational documents, and approval of major corporate transactions,
such as a change in control, merger, consolidation, or sale of assets.
Note 14. Trade Receivables, page F-31
13.Please refer to prior comment 43. Please include the proposed disclosure included in your
response.
Note 26 - Financial Instrument - b.(iii) ECL for trade receivables from contracts with customers,
page F-46
14.We note you have never recorded a write-off of a receivable based on your response to
prior comment 47.  Please tell us the amount of receivables past due for more than
one year as of March 31, 2024 that are not on additional payment arrangements or that
you have not collected a payment on in the last 12 months.  For these receivables, please
tell us why you believe you have a reasonable expectation of recovering the contractual
cash flows due and the receivable should not be written-off.  Refer to IFRS 9.B3.2.16(r)
for guidance.
15.Please refer to prior comment 47. Please include the proposed disclosure included in your
response.
16.We note your response to prior comment 48. In your response you disclose that you have
entered into additional payment arrangements with customers who have overdue balances
and that repayment plans provide a reasonable basis for expecting recovery. For all
material receivable balances past due more than 90 days, please provide us with all the
key details of these repayment plans that you rely upon as a basis for expecting recovery
including:
•details of when each agreement was put in place,
•details of new payment terms,
•collections to date,
•information related to modified amounts that have not been collected, and
•any other information material to your collectability assessment.
In this regard we note increases in your unimpaired trade receivables past due 1 year or
more and a material amount of unimpaired trade receivables from a related party past due
2-5 years as indicated in your response to comment 43. Lastly, please revise MD&A to
include appropriate detailed information related to your additional payment arrangements
to allow an investor to better understand the timing of credit impairments and the reasons
for not recognizing credit impairment on material trade receivables that are past due.

September 30, 2024
Page 5
17.We note your response to prior comment 49. Revise your disclosures to discuss
the additional payment agreements (terms, principal impacts, etc.) and how in details the
agreements impacted your assessment of credit risk, the recognition and measurement of
expected credit losses, and your write-offs.
Note 29. Subsequent Events, page F-50
18.Please refer to prior comment 51. Please include the proposed disclosure included in your
response.
Item 7. Recent Sales of Unregistered Securities, page II-2
19.We note your response to prior comment 52 and reissue in part. For each transaction listed
in this section, please state the aggregate offering price. If some of the transactions listed
in the table represent an exchange of one type of security for another type and there was
no additional consideration, please clarify that the transaction involved an exchange of
one type of share for another. As to any securities sold otherwise than for cash, state the
nature of the transaction and the nature and aggregate amount of consideration received
by you. Refer to Item 701(c) of Regulation S-K.
20.We note your response to prior comment 37 and your revised disclosure in footnote 2 to
the beneficial ownership table on page 152. In footnote 2 you state that "[t]he board of
directors of Echo International Holdings Gorup Limited holds the voting and dispositive
power over the Class A Ordinary Shares held by Echo Interntional Holdings Group
Limited." Please revise to disclose further natural persons who hold the voting and
dispositive power as described above.
            Please contact Michael Henderson at 202-551-3364 or Michael Volley at 202-551-3437 if
you have questions regarding comments on the financial statements and related matters. Please
contact Madeleine Joy Mateo at 202-551-3465 or Tonya Aldave at 202-551-3601 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Finance
cc:Lawrence Venick, Esq.