SecProbe.io

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 February 10, 2026

Michael Tannenbaum
Chief Executive Officer
Figure Technology Solutions, Inc.
100 West Liberty Street, Suite 600
Reno, NV 89501

 Re: Figure Technology Solutions, Inc.
 Amendment No. 1 to Registration Statement on Form S-1
 Filed January 28, 2026
 File No. 333-291591
Dear Michael Tannenbaum:

 We have reviewed your amended registration statement and have the
following
comments.

 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. Unless we
note otherwise,
any references to prior comments are to comments in our January 21, 2026
letter.

Amendment No. 1 to Registration Statement on Form S-1
General

1. The Division of Trading and Markets is still considering issues raised
by your
 registration statement, including the potential regulatory implications
for the National
 Market System of having both OTC and exchange-traded versions of a
common stock
 that appear to be closely linked. Trading and Markets will be reaching
out to you to
 schedule a call. In addition, TM offers the following comments 2 through
6.
2. Please describe how brokers or dealers quoting the blockchain stock over
the counter
 will comply with Rule 15c2-11 and how Figure will comply with Rule
10b-17 under the
 Exchange Act when distributing the blockchain stock. We also remind
firms to consider
 any applicable anti-manipulation and anti-fraud laws, including
Regulation M.
3. To extent that your ATS will be the only venue for trading the
blockchain stock, please
 state that. If not, please provide examples of types of trading venues
and methods of
 February 10, 2026
Page 2

 peer-to-peer transfers for a holder to buy or sell the blockchain
security on and what, if
 anything, such holder must do to trade the blockchain security at such
venue or by peer-
 to-peer method that is different than trading the blockchain stock on
the Figure ATS.
4. To the extent that your ATS will be a significant market for trading the
blockchain stock,
 please tell us how your ATS will comply with Rule 301(b)(5) of
Regulation ATS ( Fair
 Access Rule ).
5. Given the requirements of Rule 301(b)(2), including the requirement that
an ATS to file
 a material amendment on Form ATS 20 days before implementing such
change, please
 explain when subscribers to the Figure ATS will be able to trade the
blockchain stock on
 the Figure ATS.
6. We note your disclosure on page 113 that [t]he shares of blockchain
stock will initially
 be available for trading on our ATS on the same dates and during the
same market
 trading hours as our Class A common stock, as published by the NASDAQ,
 but [i]f the
 blockchain stock were permitted to trade on [the] ATS outside of NASDAQ
market
 trading hours, the trading price of the blockchain stock could differ
materially from the
 trading price of our Class A common stock. Please revise to also
disclose that the Class
 A common stock could trade on a trading center, such as an NMS Stock
ATS, during an
 overnight session, and discuss the impact of such trading on the price
of the blockchain
 stock.
7. We note your response to prior comment 6. Please clarify how holders of
blockchain
 shares exchange such shares into shares of Class A common stock pursuant
to the
 exchange offer and tell us how the movement of shares between the
blockchain stock and
 Class A common stock on your OPEN platform differs from the traditional
transfer agent
 process. In this regard, we note your disclosure on page 13 that you
intend to support
 frictionless two-way exchangeability between [your] securities issued on
OPEN and
 [your] listed Class A common stock.
Description of Capital Stock
Blockchain Common Stock, page 231

8. Refer to your response to prior comment 7. In your revised disclosure on
page 231, you
 state that dividends or other distributions to holders of blockchain
stock through
 blockchain-based representations delivered to holders' wallets
(including, at [your]
 election, in a dollar-based digital asset). Please revise to clarify
what you mean by
 blockchain-based representations and identify or further describe
the characteristics of
 the dollar-based digital asset you may use for dividends or other
distribution to holders
 of blockchain stock.
Description of Blockchain Stock
Trading and Transfers, page 236

9. We note your response to prior comment 8. Please revise to provide a
summary of how
 orders on the ATS are matched and describe the fee schedule on the ATS,
including
 which party pays the fees, so that investors understand the fees they
may owe if they
 choose to transfer shares of blockchain stock on the ATS.
 February 10, 2026
Page 3
10. We note your response to prior comment 8. Please disclose how holders of
fractional
 shares of blockchain stock exercise their voting rights. In addition,
please disclose
 whether there are any fees associated with exchanging Class A common
stock for
 blockchain common stock and whether there are any fees associated with
exchange of
 blockchain stock for Class A common stock using OPEN or otherwise.

 Please contact Madeleine Joy Mateo at 202-551-3465 or Christian Windsor
at 202-551-
3419 with any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Byron Rooney, Esq.
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