August 24, 2020
Ms. Michelle Miller
Mr. Mark Brunhofer
Division of Corporation Finance
Office of Finance
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Re: X Financial
Form 20-F for Fiscal Year Ended December 31, 2019
Filed June 4, 2020
Comment Letter Dated August 11, 2020
File No. 001-38652
Dear Ms. Miller and Mr. Brunhofer:
X Financial (the “Company”) acknowledges receipt of a comment letter from the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC” or the “Commission”) dated August 11, 2020 with respect to the Form 20-F for the fiscal year ended December 31, 2019, which was filed on June 4, 2020.
The Company has carefully reviewed and considered the Staff’s comments, and is in the process of preparing a response to these comments. Regrettably, the Company believes that it will not be in a position to respond to the Staff’s comments within ten business days, as requested by the Staff. It would need additional time to collect sufficient information and perform thorough analysis. The Company expects to be in a position to respond to the Staff’s comments by September 4, 2020 and appreciates the Staff’s accommodation in this regard.
Should you have any questions regarding the foregoing or require any additional information, please do not hesitate to contact me at +86 13910503629 (frank.zheng@xiaoying.com) or Mr. Li He of Davis Polk & Wardwell LLP at +852 2533 3306 (li.he@davispolk.com). Thank you very much for your assistance.
Sincerely, |
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/s/ Frank Fuya Zheng |
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Name: | Frank Fuya Zheng |
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Title: | Chief Financial Officer |
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cc: Li He, Davis Polk & Wardwell LLP
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No. 168, Haide Third Avenue, Nanshan District
Shenzhen, 518067, the People’s Republic of China