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 1271 Avenue of the Americas

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 www.lw.com

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September 2, 2025 Chicago Riyadh

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Division of Corporation Finance Office of Finance

United States Securities and Exchange Commission 100 F

Street, N.E.

Washington, D.C. 20549

 Los Angeles Washington, D.C.

Madrid

Attention: Ben Phippen, Cara Lubit, Madeleine Joy Mateo, James Lopez

Re: Figure Technology Solutions, Inc.

 Form S-1 Filed August 18, 2025

 CIK No. 0002064124

Ladies and Gentlemen:

Figure Technology Solutions, Inc., a Nevada corporation (the “Company”), has filed with the U.S. Securities and Exchange Commission (the “Commission”) on the date hereof an amendment (“Amendment No. 2”) to the Registration Statement on Form S-1 (the “Registration Statement”). The Company previously filed the Registration Statement on August 18, 2025. The Registration Statement has been revised to address the comments received from the staff of the Commission (the “Staff”) on the Registration Statement. The bold and numbered paragraphs below correspond to the numbered paragraphs in the Staff’s letter and are followed by the Company’s responses. Page references in the text of this letter correspond to the pages of the Registration Statement. Unless otherwise indicated, capitalized terms used herein have the meanings assigned to them in the Registration Statement. The responses and information described below are based upon information provided to us by the Company.

Registration Statement on Form S-1

A Letter From Our Founder, page ii

1.We note the reference to the GENIUS Act and related regulations here and on page 99. Please revise page 99 and where appropriate to update for enactment and discuss the extent to which your YLDS stablecoin or other assets, such as nuYLDS or other digital assets on Figure Exchange or other parts of your ecosystem, could be deemed to be subject to the legislation. Additionally, we note the reference to

September 2, 2025

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five parties intermediating debit cards and your marketplace limiting the parties to just the buyer and seller such that “[a]ll the rent-seeking goes away.” With a view to clarifying disclosure, advise us whether the various roles you play and the ecosystem fees you charge bring in a necessary third party beyond the buyer and seller, for example your transfer agent’s role collecting and maintaining personally identifiable information or your responsibility in mirroring the “order book on Figure Exchange,” as stated on page 190.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on page 101. The Company further advises the Staff that NuYLDS is not a Company product, nor does it currently exist, however, if it is created and is subsequently added to the Figure Exchange, and it falls under the legislation, Figure Exchange will comply with the legislation accordingly. In addition, the Company advises the Staff that the example of multiple intermediating parties involved in each credit card transaction and reference to rent-seeking was meant to describe the power of blockchain, which has the ability to remove multiple parties and create a more efficient market, rather than a Company-specific example regarding the use of our platform or product.

Our Solutions, page 4

2.We note your response to prior comment 5. Please advise us of the following:

•What are “vaults” and a “vault marketplace”? It is unclear if these are the same types of vaults as are referenced on page 184 as “secure electronic vaults”;

•How do (or will, if this is a prospective offering) vaults and a vault marketplace interact within and/or apart from Figure Exchange and the other parts of your business?

•Would nuYLDS or the vaults or vault marketplace present offerings that compete with Figure Exchange or other parts of your business?; and

•Are there risks associated with such strategic partnerships that should be addressed in your prospectus.

Please revise or advise.

Response: The Company advises the Staff that nuYLDS, vault and vault marketplace are third party products unrelated to the Company. As previously referenced in a prior response letter, Animoca is a firm that may buy our tokenized assets much like any other buyer. These Aminoca products do not compete with Figure Connect but in fact are additional potential buyers on Figure Connect for tokenized assets. As discussed with the Staff, the Company is confused by certain of the statements made in the Animoca press release, and the

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Company has no control over the content it releases. Given the above, there are no associated risks of the Aminoca products.

Figure Connect, page 7

3.We note your response to prior comment 4 and your disclosure that the Guarantor Vehicle has yet to purchase HELOCs via Figure Connect but has instead purchased $25 million of residual equity from your securitization completed in May 2025. Noting also your response that you use the term “Guarantor” because the Guarantor Vehicle assumes the first loss or residual position in its securitizations by holding the equity portion of those securitizations on its balance sheet, please advise us, with a view to clarifying disclosure, of the following:

•If the Guarantor Vehicle is obligated to and will continue to purchase an equity portion of each securitization and describe any related underlying agreements governing this obligation. If applicable, describe instances wherein the Guarantor Vehicle is not obligated to purchase an equity portion of securitizations;

•How “first loss” is defined and what quantitative and/or qualitative factors are used to determine the residual position;

•What risks you are exposed to in the JV taking the first loss or residual position in securitizations;

•Any limitations to the JV’s assumption of first loss in the securitizations (dollar amount, percentage, etc.); and

•If the assumption by the Guarantor Vehicle of the first loss or residual position in securitizations extends to third party investors.

Additionally, please disclose whether, once the Guarantor Vehicle begins purchasing HELOCs via Figure Connect, the Guarantor Vehicle will be obligated to purchase HELOCs, any related underlying agreements governing this obligation, and any limitations wherein the Guarantor Vehicle will not purchase HELOCs. In this regard, we note your disclosure on page 8 that the Guarantor Vehicle is specifically mandated to purchase and securitize assets sold via Figure Connect.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 8, 190 and 191 in response to each of the bullet points above.

4.Additionally, as you continue to use the term “Guarantor,” please revise to clarify whether and to what extent there is an indirect guarantee, as

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suggested by the statement that the vehicle “does not directly provide a guarantee or backing of the loans.”

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 8, 190 and 191.

Figure Exchange, page 9

5.We note your response to prior comment 6 and revised disclosure on page 188 stating that Democratized Prime “connects asset owners looking to borrow against those assets with liquidity providers seeking to earn yield by lending to those assets.” It is still unclear who the users and other parties are and how users choose the most appropriate and efficient pool for their unique use case. Please revise to provide a graphic or other explanatory disclosure that identifies the parties to a typical transaction, the typical asset involved, and the typical interest rate. In this regard, we note your website includes the statement that “[i]nvestors access overcollateralized, short-duration claims tied to real assets, starting with mortgage warehouse lines, through a structure designed for daily settlement and clear reporting.” As non- exclusive examples of disclosures that may be appropriate for clarification based on information from your website, it is unclear how assets are pooled, how many lenders and borrowers may be involved in a single transaction, how warehouse lines play a role, and whether and how you or your agreements with users ensure that any LTV exceeding 90% gets “automatically liquidate[d]” to repay loans. Please revise accordingly.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 9, 10, 11, 192, 193 and 194.

Tokenization and Trading, page 12

6.We note your response to prior comments 2 and 16 and revised disclosure, including on pages 2, 12, 184 and 195. It is unclear why you state that Provenance is the sole system of record when you also state on page 2 that the blockchain is a validation mechanism to “support the traditional, off-chain processes [you] use for tracking and monitoring loan transactions.” As other examples of off-chain records and activities that appear to set up a hybrid system of record, we note the following:

•References on page 12 and elsewhere to real-world asset representations documented through traditional legal documents that record real-world assets pursuant to state laws;

•Statements throughout that personally identifiable information of the borrower is not recorded on a public blockchain; and

•The statement on page 184 that “data and the documents collected in the origination process are digitally stored in a secure electronic vault outside of the Provenance Blockchain.”

September 2, 2025

Page 5

Please revise Our Solutions on page 4 and other descriptions of the blockchain as your “sole system of record” to further clarify the apparently hybrid nature of the documentation, reconciliation and other processes associated with your systems. Additionally, we also note your statement on page 12 and elsewhere that you contractually require all owners of tokenized real-world assets to reflect all asset transactions on the Provenance Blockchain and to pass the same obligation along to any subsequent owner, as well as the statement on page 184 that loan owners use the Portfolio Manager to transfer loans by transferring the tokens and “access rights to the loan file in the secure electronic vault.” With a view to clarifying disclosure in Risk Factors, advise us of the risks and/or limitations associated with downstream purchasers. For example, could they intentionally or unintentionally not comply with the obligation?

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 15, 201, 202, 187 and 188.

7.Please clarify if the owners of tokenized real-world assets with which you have contractual agreements also own the real-world assets. To the extent the owners are not the same, clarify if there are any agreements in place that require changes to or transactions concerning real-world assets to also be reflected on the blockchain. Further describe here how the design of your systems makes it impractical to transfer ownership without the use of blockchain-based systems.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 15, 201 and 202.

8.We note your statement in response to prior comment 2 that the current principal business is the tokenization of loans and not the tokenization of securities. However, we note the statement on page 17 discussing your tokenization of digital assets and belief that the market opportunity for tokenized securities is as large as the existing securities market. To the extent you have definite plans to tokenize securities as a material part of your business, please revise and advise us with respect to the tokenization of securities as requested in prior comment 2. For example, summarize important limitations or risks associated with transacting in or holding tokenized securities, including whether all relevant parties would be made aware of or allowed to participate in potential creation and transfer of tokenized securities.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on pages 18 and 230 to remove the disclosure regarding the market opportunity for tokenized securities. The Company further advises the Staff that, while tokenized securities may be a potential product, the Registration Statement does not contemplate definitive plans to tokenize securities as a central part of the Company’s tokenization of loans’ business. Tokenized securities are not a product the Company currently offers and is just an example of something that could come on blockchain. In the event that this is

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something the Company will definitively pursue, the Company will update its current reports or any future registration statements to summarize important limitations or risks associated with transacting in or holding tokenized securities.

9.Please refer to prior comment 16 and the request for clarification of reconciliation processes. To the extent material to an understanding of key aspects of your blockchain and related business, including technological competitiveness and/or the risks described on pages 43-46, please clarify the statement on page 184 that the “hash can detect any subsequent changes to the data and documents, allowing for verification of authenticity.” It is unclear how hash is used in the reconciliation or verification process, how it can detect changes, and what types of changes are detected. It is also unclear who is involved in this process. For example, when hash detects a change, it is unclear who verifies and authenticates it and how these steps are viewed by the lender, borrower, purchaser, and so forth. Additionally, it appears that reconciliation is only possible where the servicer or sub-servicer has agreements with you and has connected their software to the Provenance Blockchain. Please revise to provide clarification, including a summary, if true, of how your agreements with third parties obligate them to use your Portfolio Manager and the Provenance Blockchain. If third parties are able to use LOS for underwriting and/or originating while opting out of some or all of the blockchain-related features, please revise to clarify.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on page 187 and 188.

Homogeneous underwriting, page 14

10.We note your response to prior comment 8. Please revise your disclosure to discuss, as you discuss in your correspondence, that you collect FICO scores as part of the digital assets-backed loans origination process but do not use FICO scores in the digital assets-backed loan underwriting, and disclose the required minimum draw down amounts at origination.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on page 16.

Organizational History, page 20

11.We note your response to prior comment 1. Please revise the graphic on page 21 and accompanying discussion to connect your key operations, such as HELOC originations and LOS, with the corresponding entities in the organizational structure. In this regard, it is unclear why FCC is not identified.

Response: The Company respectfully acknowledges the Staff’s comment and has revised the disclosure on page 23.

September 2, 2025

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Key Operating Metrics, page 141

12.We note your response to prior comment 12 and your revised disclosure on pages 149 and 158 clarifying that technology fees are only earned on a subset of Partners included in the Partner Branded Volume repor