June 14, 2019

Renhui Mu
Chairman and Chief Executive Officer
Wins Finance Holdings Inc.
1F, Building 7
No. 58 Jianguo Road, Chaoyang District
Beijing 100024, People's Republic of China

       Re: Wins Finance Holdings Inc.
           Form 20-F
           Filed October 31, 2018
           Response Dated May 31, 2019
           File No. 333-204074

Dear Mr. Mu:

       We have reviewed your May 31, 2019 response to our comment letter and
have the
following comments. In some of our comments, we may ask you to provide us with
information
so we may better understand your disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
May 2, 2019 letter.

Form 20-F filed October 31, 2018

Financial Statements, page F-4

1.    We note your response to comment 8. Your response does not appear to
address the
      information requested in the comment so we are reissuing comment 8.
2.    We note your response to comment 9 and your example journal entries.
Based on your
      example journal entries, it appears that you have a remaining debit
balance of $82 in
      Guarantee paid on behalf of guarantee service customers (B/S) offset with
a credit balance
      of $82 in Allowance on guarantee (B/S). Using the same fact pattern
provided in
      comment 9 please explain these balances and show the entries used to
reduce these
      amounts.
 Renhui Mu
Wins Finance Holdings Inc.
June 14, 2019
Page 2
3.       We note your response to comment 10. Your proposed draft disclosure
does not appear to
         address the information required by ASC 310-10-50. Please revise
future filings to
         disclose the information required by ASC 310-10-50 for your receivable
from guarantee
         customers as applicable and provide a draft of your proposed
disclosure.
Consolidated Statements of Cash Flows, page F-7

4.       We note your response to comment 11. Your proposed draft disclosure
does not appear to
         address the reconciliation between the line items "deposit paid to
banks for financial
         guarantee services" and "deposit released from banks for financial
guarantee services" to
         the presentation of "restricted cash" used in the balance sheet.
Please revise your
         Statement of Cash Flows presentation in future filings to allow an
investor to understand
         how changes in the balance sheet line item "restricted cash" is
presented in the Statement
         of Cash Flows. Please provide a draft of your proposed disclosure.
Notes to the Unaudited Consolidated Financial Statements
Note 2. Summary of Significant Accounting Policies
(f) Short-term investments, page F-11

5.       We note your response to comment 13. It does not appear your
short-term investments
         meet the criteria to be scoped out of ASC 320-10. Please tell us the
specific guidance you
         relied on to scope out your short term investments under ASC 320 or
revise to account for
         the securities as available-for-sale securities and provide the
information required by ASC
         320-50.
Note 7. Net Investment in Direct Financing Leases, page F-23

6.       We note your response to comment 14 and your proposed revised
disclosure. Please
         revise future filings to further break out the amounts included in the
"Overdue and credit-
         impaired" bucket into separate past due buckets (e.g. > 90 days past
due, > 180 days past
         due, etc.). Refer to the example disclosure in ASC 310-10-55-9. Please
include a draft of
         your proposed disclosure for each period presented.
       You may contact William Schroeder, Staff Accountant, at 202-551-3294 or
Michael
Volley, Staff Accountant, at 202-551-3437 with any questions.



FirstName LastNameRenhui Mu                                    Sincerely,
Comapany NameWins Finance Holdings Inc.
                                                               Division of
Corporation Finance
June 14, 2019 Page 2                                           Office of
Financial Services
FirstName LastName