April 9, 2020

Paul Wallace
Chief Executive Officer
FEC Resources Inc.
Suite 2300, Bentall 5, 550 Burrard Street
Vancouver, BC, V6C 2B5

       Re: FEC Resources Inc.
           Amendment No. 2 to Registration Statement on Form F-1
           Filed March 27, 2020
           File No. 333-235559

Dear Mr. Wallace:

      We have reviewed your amended registration statement 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 this letter by amending your registration statement
and providing the
requested information. If you do not believe our comments apply 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 these comments, we may have additional comments. Unless
we note
otherwise, our references to prior comments are to comments in our February 13,
2020 letter.

Amendment No.2 to Registration Statement on Form F-1

General

1.     We note your response to prior comment 2. Please revise your disclosure
to include a risk
       factor regarding the possibility that you may be considered an
investment company under
       Section 3(a)(1) of the Investment Company Act of 1940 (the Act), and
explain that you
       intend on relying on the exclusion under Section 3(c)(9) of the Act and
the reasons why it
       may be available to you. Please also disclose the material consequences
to the company
       that could occur if the company were deemed to be an investment company.
In your
       revised disclosure, please clarify that the staff has not taken a
position whether you may
       rely on such exclusion. Additionally, please be advised that you are
responsible for
       analyzing how your investments, investment strategy and business model
will support the
 Paul Wallace
FEC Resources Inc.
April 9, 2020
Page 2
      respective exclusion from the Act.
2.    Please update throughout your registration statement, including your
Management's
      Discussion and Analysis of Financial Condition and Results of Operations
section, for the
      financial information for the fiscal year ended December 31, 2019. Please
also revise
      page 41 to provide the executive compensation disclosures for the fiscal
year
      ended December 31, 2019.
      Please contact Timothy S. Levenberg, Special Counsel, at (202) 551-3707
or Lauren
Nguyen, Legal Branch Chief, at (202) 551-3642 with any questions.



                                                          Sincerely,
FirstName LastNamePaul Wallace
                                                          Division of
Corporation Finance
Comapany NameFEC Resources Inc.
                                                          Office of Energy &
Transportation
April 9, 2020 Page 2
cc:       Scott Lawler, Esq.
FirstName LastName