SecProbe.io

November 19, 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. 2 to Draft Registration Statement on Form F-1
Submitted November 5, 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 September 30, 2024 letter.
Amendment No. 2 to Draft Registration Statement on Form F-1
General
1.We note your response to prior comment 2. We also note your reference to your
trading platform on page 29. Please revise your disclosure to further describe your
trading platform and the relevance to your business. In this regard, we note your
disclosure on page 107 that your client may place trading orders (i) by phone; or (ii)
onsite at your office premises by submitting an order ticket, which can be accessed by
mobile device application. If applicable here, describe the trading platform you
reference.

November 19, 2024
Page 2
Prospectus Summary
Overview, page 1
2.We note your response to prior comment 1 and reissue our comment. Please revise
this section to list separately the three types of services you appear to provide: 1)
consulting and advisory services, 2) commodity trading, and 3) financial services. List
them in the order of services that produce the most revenues for your company. In this
regard, we note your response to comment 9 where you stated that "underwriting and
placing services, securities brokerage and dealing services, and asset management
services segments differ from consulting and advisory services segment." You
continue, however, to describe all these types of services under financial services and
combine them together. In addition, given the differences in the total revenue derived
from consulting and advisory services (57.05% and 77.5% for the years ended March
31, 2024 and 2023) compared to the total revenue derived from your other financial
services, such as underwriting and placing services, securities dealing and brokerage
services, and asset management services (in the aggregate, 2.49% and 3.23% for the
same periods, respectively), please revise your disclosure in this section to describe in
more detail your consulting and advisory services as you did in the business section.
Your current disclosure appears to indicate that you have derived over 57% of your
revenues in the most recent fiscal year from what appears to be effectively general
business consulting and advisory services, not financial or underwriting
services. Investors should be able to readily discern from the presentation of your
disclosure your material lines of business.
Business
Overview, page 100
3.We note your response to prior comment 9 and reissue our comment. Please revise
this section to list separately the three types of services you appear to provide: 1)
consulting and advisory services, 2) commodity trading, and 3) financial services. List
them in the order of services that produce the most revenues for your company. In this
regard, we note your response to comment 9 where you stated that "underwriting and
placing services, securities brokerage and dealing services, and asset management
services segments differ from consulting and advisory services segment."
You continue, however, to describe all these types of services under "financial
services" and combine them into one. As such, revise this subsection significantly as
follows:
•describe how you are compensated for each of the services provided, such as
commissions, flat fees or otherwise;
•revise disclosure about your consulting and advisory services segment separately,
as opposed to listing it within the "financial services business segment;" and
•because you derive most of your revenues from business consulting and advisory
services, move the description of this business segment to the beginning of the
business section, as opposed to listing financial services as the first segment
because it only produced less than 4% of your revenues in the last two fiscal
years.

November 19, 2024
Page 3
External Brokers, page 108
4.We note your response to prior comment 10. Please file all material agreements with
Phillip Securities Limited as exhibits or advise.
Principal Shareholders, page 150
5.We note your response to prior comment 12 and your revised disclosure in footnote 6
to the beneficial ownership table. Please revise your disclosure in the section prior to
the table to disclose the percentage of outstanding Class A shares  the holders of Class
A ordinary shares must keep to continue to control the outcome of matters submitted
to shareholders for approval. It appears based on your disclosure that your significant
beneficial owners do not currently hold any Class B ordinary shares.
6.We note your response to prior comment 20 and your revised disclosure in
footnote (2) to the beneficial ownership table. Please further revise your disclosure in
footnote (2) to state that the enumerated natural persons have the voting and
dispositive power over the shares owned by Echo Interntional Holdings Group
Limited or revise to state who has the voting and dispositive power.
Note 26 - Financial Instrument - b.(iii) ECL for trade receivables from contracts with
customers, page F-47
7.We note your response to prior comment 14 and the disclosure of your write-off
policy on page F-20. It appears that your policy of writing-off a receivable when,
"there is no realistic prospect of recovery" may not be consistent with the guidance in
IFRS 9 which indicates an entity should write-off a financial asset when the entity
has "no reasonable expectations of recovering the contractual cash flows" which could
result in you delaying the write-off of certain receivables. It appears that receivables
not on additional payment arrangements, for which you have not received a payment
in a reasonably long time, and for which the customer has not acknowledged the
outstanding debts may meet the "no reasonable expectation" criteria in IFRS 9. Please
ensure you properly assess your receivables to determine when you have no
"reasonable expectations" and write-off your receivables accordingly.  Please revise
the disclosure of your write-off policy as needed.
8.We note your response to prior comment 15. It appears you did not include certain
material information that was included in your proposed revised disclosure
from comment 47 in our letter dated July 19, 2024. Therefore, please include the
following information in the appropriate section of your filing:
•When assessing expected credit losses, defaulted receivables are subject to higher
provisions compared to non-defaulted receivables. This is to account for the
increased credit risk associated with defaults.

November 19, 2024
Page 4
            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.