SEC Company Response from Beta FinTech Holdings Ltd (BTFT) (CIK 0002046216) — Sep 12, 2025
Beta FinTech Holdings Ltd (BTFT) (CIK 0002046216)
Date: Sept. 12, 2025 · CIK: 0002046216 · Accession: 0001213900-25-087165
AI Filing Summary & Sentiment
File numbers found in text: 333-287759
Referenced dates: September 9, 2025
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CORRESP
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filename1.htm
Xiaoqin ("Sherry") Li
Senior Counsel
345 Park Avenue
New York, NY 10154
Direct 212.407.4939
Main 212.407.4000
Fax 212.407.4990
xli@loeb.com
September 12, 2025
Xianxin Xiang
Chief Executive Officer
Beta FinTech Holdings Ltd
Rm 3326, East Block, China Merchants Tower
168-200 Connaught Road Central, Sheung Wan,
Hong Kong
Re: Beta FinTech Holdings Ltd
Amended Form F-1 filed August 12, 2025
File No. 333-287759
Dear Messrs. Schiffman and Lopez:
On behalf of our client, Beta FinTech
Holdings Ltd (the “Company”), we hereby provide a response to the comments issued in a letter dated September 9, 2025 (the
“Staff’s Letter”) regarding the Company’s Amendment No. 3 to Registration Statement on Form F-1 filed August 12,
2025. Contemporaneously, we are filing an Amendment No. 5 to Registration Statement on Form F-1 (the “Amendment No. 4”) via
Edgar.
In order to facilitate the review by the staff of the Securities and
Exchange Commission (the “Staff”) of the Amendment No. 4, we have responded, on behalf of the Company, to the comments set
forth in the Staff’s Letter on a point-by-point basis. The numbered paragraphs set forth below respond to the Staff’s comments
and correspond to the numbered paragraph in the Staff’s Letter.
Amended Form F-1 filed August 12, 2025
Summary, page 1
1. Please fill in the information currently in brackets on page 1, "We maintain a corporate website at [ ]." We also note the
brackets on pages 117 and 134. Please revise accordingly..
Response: In response to the Staff’s
comments, the Company has revised the disclosures on pages 1, 117 and 134 of the Amendment No. 4.
September 12, 2025
Page 2
2. With respect to the discussion of your offering being contingent on Nasdaq approval, please revise to disclose the status of the application
process. We also note the reference on page 4 to a joint statement by the SEC, proposed rule changes submitted by Nasdaq, and an act passed
by the U.S. Senate and the U.S. House of Representatives. Please revise here and Risk Factors to more specifically identify and update
these statements and dates.
Response: Nasdaq is in the process
of reviewing the Company’s listing application so there is no update to the disclosure of the application process yet. In response
to the Staff’s other comments, the Company has revised the disclosures on pages 4, 27, 28, 31 and 37 of the Amendment No. 4.
Please call me at 212-407-4939 if you would like
additional information with respect to any of the foregoing. Thank you.
Sincerely,
/s/ Xiaoqin (Sherry) Li
Xiaoqin ("Sherry") Li
Senior Counsel