February 3, 2020

Luke D'Angelo
Chief Executive Officer
AppTech Corp.
2032 Corte Del Nogal, Suite 120
Carlsbad, CA 92011

       Re: AppTech Corp.
           Amendment No. 1 to Registration Statement on Form 10-12G
           Filed January 27, 2020
           File No. 000-27569

Dear Mr. D'Angelo :

       We have reviewed your filing 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 and any amendment you may file in response
to these
comments, we may have additional comments. Unless we note otherwise, our
references to prior
comments are to comments in our January 8, 2020 letter.

Registration Statement on Form 10

Security Ownership of Certain Beneficial Owners and Management, page 19

1.    We note your response to prior comment 6. Please revise the beneficial
ownership table
      to reflect all beneficial owners of more than 5% of each class of voting
securities,
      including your Series A Preferred Stock. Refer to Item 403(a) of
Regulation S-K for
      guidance.
Executive Compensation, page 21

2.    Please update to disclose executive compensation awarded in fiscal year
ended December
      31, 2019. See Item 402(n) of Regulation S-K.
 Luke D'Angelo
FirstName LastNameLuke D'Angelo
AppTech Corp.
Comapany NameAppTech Corp.
February 3, 2020
Page 2
February 3, 2020 Page 2
FirstName LastName
        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       You may contact Inessa Kessman, Staff Accountant, at (202) 551-3371 or
Joseph Kempf,
Staff Accountant, at (202) 551-3352 if you have questions regarding comments on
the financial
statements and related matters. Please contact Matthew Derby, Staff Attorney,
at (202) 551-
3334 or Jan Woo, Legal Branch Chief, at (202) 551-3453 with any other
questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Technology
cc:      Andy Tucker