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SEC Company Response from XFLH Capital (XFLH) — Jan 28, 2026

XFLH Capital Corp
Date: Jan. 28, 2026 · CIK: 0002088103 · Accession: 0001185185-26-000326

Offering / Registration Process Regulatory Compliance Business Model Clarity

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File numbers found in text: 333-290588

Date
January 30, 2026
Author
XFLH CAPITAL CORPORATION
Form
CORRESP
Company
XFLH Capital Corp

Letter

XFLH CAPITAL CORPORATION

8 The Green #6565

Dover, DE, 19901

January 28 th , 2026

VIA EDGAR

Division of Real Estate & Construction

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Attention:

Ms. Babette Cooper Mr. Wilson Lee Mr. Benjamin Holt Mr. Jeffrey Gabor

Re: XFLH Capital Corporation - Initial Public Offering

SEC Registration Statement S-1

(SEC File Number: 333-290588) (the "Registration Statement")

Ladies and Gentlemen:

The Company hereby requests, pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the Registration Statement so that such Registration Statement will become effective at 5:00 P.M., Washington D.C. time, on January 30, 2026 or as soon thereafter as practicable.

The Company hereby acknowledges that:

● Should the Securities and Exchange Commission (the "Commission") or the Staff, acting as pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

● The action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

● The Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Very truly yours,
XFLH CAPITAL CORPORATION

Show Raw Text
CORRESP
 1
 filename1.htm

 XFLH CAPITAL CORPORATION

 8 The Green #6565

 Dover, DE, 19901

 January 28 th , 2026

 VIA EDGAR

 Division of Real Estate & Construction

 Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

 Attention:

 Ms. Babette Cooper
 Mr. Wilson Lee
 Mr. Benjamin Holt
 Mr. Jeffrey Gabor

 Re:
 XFLH Capital Corporation - Initial Public Offering

 SEC Registration Statement S-1

 (SEC File Number: 333-290588) (the "Registration
Statement")

 Ladies and Gentlemen:

 The Company hereby requests,
pursuant to Rule 461 promulgated under the Securities Act of 1933, as amended, acceleration of effectiveness of the Registration Statement
so that such Registration Statement will become effective at 5:00 P.M., Washington D.C. time, on January 30, 2026 or as soon thereafter
as practicable.

 The Company hereby acknowledges
that:

 ● Should
the Securities and Exchange Commission (the "Commission") or the Staff, acting as pursuant to delegated authority, declare
the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration Statement;

 ● The
action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does
not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the Registration Statement; and

 ● The
Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

 Very truly yours,

 XFLH CAPITAL CORPORATION

 By:
 /s/ Yanzhe Yang

 Name:
 Yanzhe Yang

 Title:
 Chief Executive Officer

 cc:

 Bill Huo, Esq. (via email)

 Michael Goldstein, Esq. (via email)

 Fiona Wu, Esq. (via email)