New York | Paris | |||||
Northern California | Madrid | |||||
Washington DC | Tokyo | |||||
São Paulo | Beijing | |||||
London | Hong Kong | |||||
James C. Lin | ||||||
Partner | Resident Hong Kong Partners | |||||
Davis Polk & Wardwell | 852 2533 3368 tel | William F. Barron* | Gerhard Radtke* | |||
Hong Kong Solicitors | 852 2533 1768 fax | Bonnie Chan* | Martin Rogers † | |||
The Hong Kong Club Building | james.lin@davispolk.com | Karen Chan† | Patrick S. Sinclair* | |||
3A Chater Road | Paul K. Y. Chow*† | Miranda So* | ||||
Hong Kong | James C. Lin* | James Wadham† | ||||
Hong Kong Solicitors | ||||||
*Also Admitted in New York | ||||||
† Also Admitted in England and Wales |
November 2, 2018
Re: | CNFinance Holdings Limited (CIK No. 0001733868) |
Registration | Statement on FormF-1 (File No.333-226126) |
Mr. Michael Clampitt
Mr. David Lin
Mr. Michael Henderson
Mr. H. Stephen Kim
Office of Financial Services
Division of Corporation Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Dear Mr. Clampitt, Mr. Lin, Mr. Henderson and Mr. Kim:
On behalf of our client, CNFinance Holdings Limited, an exempted company incorporated under the laws of the Cayman Islands (the “Company”), we submit to the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) this letter in connection with the Company’s registration statement on FormF-1 (the “Registration Statement”) initially filed on July 11, 2018, with amendment No. 1 to the Registration Statement (the “First Amended Registration Statement”) filed on July 31, 2018, amendment No. 2 to the Registration Statement (the “Second Amended Registration Statement”) filed on August 24, 2018 and amendment No. 3 to the Registration Statement (the “Third Amended Registration Statement”) filed on October 31, 2018. Concurrently with the submission of this letter, the Company is filing its amendment No. 4 to the Registration Statement (the “Fourth Amended Registration Statement”) and exhibit 1.1 via EDGAR to the Commission.
The Company plans to request that the Staff declare the effectiveness of the Registration Statement on November 6, 2018, and is filing the joint acceleration requests concurrently with the filing of the Amended Registration Statement. The Company would greatly appreciate the Staff’s continuing assistance to clear outstanding written or oral comments and support in meeting its timetable.
Securities and Exchange Commission | 2 | November 2, 2018 |
If you have any questions regarding this submission, please contact me at+852-2533-3368 or james.lin@davispolk.com.
Thank you for your time and attention.
Yours sincerely, |
/s/ James C. Lin |
James C. Lin |
cc: | Mr. Bin Zhai, Chief Executive Officer | |
Mr. Ning Li, Chief Financial Officer | ||
CNFinance Holdings Limited | ||
Mr. David T. Zhang, Esq. | ||
Mr. Steve Lin, Esq. | ||
Mr. Meng Ding, Esq. | ||
Kirkland & Ellis International LLP | ||
Mr. Ivan Li | ||
KPMG Huazhen LLP |