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                             February 16, 2021

       Takumi Kitamura
       Executive Managing Director and Chief Financial Officer
       Nomura Holdings, Inc.
       9-1 Nihonbashi 1-chome
       Chuo-ku, Tokyo 103-8645
       Japan

                                                        Re: Nomura Holdings,
Inc.
                                                            Form 20-F for the
Fiscal Year Ended March 31, 2020
                                                            Filed June 30, 2020
                                                            File No. 001-15270

       Dear Mr. Kitamura:

              We have limited our review of your filing to the financial
statements and related
       disclosures 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 10 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.

       Form 20-F for the Fiscal Year Ended March 31, 2020

       Item 5. Operating and Financial Review and Prospects
       A. Operating Results, page 48

   1.                                                   From your earnings
conference call for the quarter ended September 30, 2020 held on
                                                        October 28, 2020 and
the accompanying slide deck (as well as the slide deck for your
                                                        earnings conference
call for the quarter ended December 31, 2020) we note your
                                                        presentation of the
following key performance indicators (KPIs) that do not appear to be
                                                        presented and discussed
in your Form 20-F:
                                                            From slide 8
(September quarter) and slide 9 (December quarter) for your Retail
                                                            segment:
                                                              o   Recurring
revenue assets and recurring revenue; and
                                                              o   Active
clients;
                                                            From slide 11
(September quarter) and slide 12 (December quarter) for
 Takumi Kitamura
FirstName LastNameTakumi  Kitamura
Nomura Holdings, Inc.
Comapany16,
February  NameNomura
            2021       Holdings, Inc.
February
Page 2 16, 2021 Page 2
FirstName LastName
             your Wholesale segment:
               o   Cost-income ratio; and
               o   Revenue as a percentage of modified risk-weighted assets.
         As you identify these measures as KPIs, please represent to us that
you will include them
         as well as a discussion of how they are derived, how you use them and
why they changed
         period over period in your future filings on Form 20-F. Otherwise,
tell us where you have
         made these disclosures or explain to us why such disclosure is not
warranted.
Results by Business Segment
Wholesale, page 55

2.       In the fourth paragraph and the last paragraph on page 56, you
disclose that your net
         revenue figures for your Global Markets and Investment Banking
business, respectively,
         are non-GAAP financial measures. Please address the following:
             Provide us the reconciliations for these non-GAAP measures to the
most directly
              comparable GAAP measures for each period presented as required by
Item
              10(e)(1)(i)(B) of Regulation S-K or tell us where you provided
this reconciliation in
              your filing;
             Confirm for us that the most directly comparable GAAP measure for
your Investment
              Banking business is your "fees from investment banking" as
presented in the table in
              Note 4 on page F-72 or explain to us why these amounts are not
the most directly
              comparable GAAP measures; and
             Tell us why you reflect each adjustment in the reconciliations
requested in the first
              bullet above and explain how each does not represent a tailored
recognition and
              measurement method as contemplated in Question 100.04 of the
Compliance and
              Disclosure Interpretations on Non-GAAP Financial Measures.
Notes to the Consolidated Financial Statements
Note 1: Summary of accounting policies
Future accounting developments, page F-31

3.       You disclose the   15,662 million impact of adopting ASU 2016-13 on
April 1, 2020 as it
         relates to financial instruments for which you elected the fair value
option. We note
         similar disclosure on page F-13 of your Interim Operating and
Financial Review for
         September 30, 2020 as provided as Exhibit 1 to your Form 6-K filed on
December 18,
         2020. Please provide us a summary of your accounting for the adoption
of ASU 2016-13
         for these financial instruments and reference for us the authoritative
literature you relied
         upon to support your accounting. In your response, specifically tell
us:
             The principal amount and amortized cost of the loans receivables
at March 31, 2020
              that are now carried under the fair value option;
             The cause of the aggregate   9,774 million decrease in loans
receivable explaining
              why fair value significantly below amortized cost is not
indicative of impairment
              under the incurred loss model prior to adoption of ASU 2016-13;
             The composition of the   5,888 of other liabilities recorded and,
to the extent
 Takumi Kitamura
FirstName LastNameTakumi  Kitamura
Nomura Holdings, Inc.
Comapany16,
February  NameNomura
            2021       Holdings, Inc.
February
Page 3 16, 2021 Page 3
FirstName LastName
              applicable, the aggregate unfunded loan commitments underlying
this liability;
                Why you elected to treat these loans and loan commitments under
the FVO as
              opposed to those you previously reflected under the FVO as well
as those
              you continue to carry at amortized cost and your consideration
for providing this
              disclosure in future financial statements under ASC 825-10-50-28a
and 50-28b, or
              tell us where you have made this disclosure in your September 30,
2020 Interim
              Operating and Financial Review Report; and
                Your consideration for providing the other disclosures from ASC
825-10-50-28 as
              well as those in 50-29 and 50-30 in future financial statements
or tell us where you
              have made these disclosures in your September 30, 2020 Interim
Operating and
              Financial Review Report.
Note 4: Revenue from services provided to customers
Revenue by type of service, page F-72

4.       We note your disaggregation of revenues from services provided to
customers. Please
         address the following:
             Tell us how your disaggregation provides information regarding the
timing of
             revenue as stipulated in ASC 606-10-50-5 when, for example some of
your fees as
             outlined beginning on page F-73 are recognized at a point in time
while others are
             recognized over time;
             Tell us your consideration for disclosing your revenue by
product/service or group of
             product/service as stipulated in ASC 280-10-50-40 or tell us where
you have made
             this disclosure. In your response tell us your consideration of
the following
             observations:
               o   You provide revenue by product/service for your Retail
segment in Item 5 on
                   page 51, but do not provide this level of detail in the
footnotes for either
                   this segment or the entire company.
               o   You do not appear to provide any level of granularity for
revenue in your Asset
                   Management segment other than non-interest revenue and
interest revenue in
                   Item 5 on page 53 and the segment Note 22 on page F-138.
Although you do
                   not appear to disclose revenue by type for this segment, we
note that
                   you disclose assets under management (AUM) by subsidiary on
pages 53 and
                   54, but the disclosure of AUM and associated revenues by
Investment Trust
                   business and Investment Advisory business as presented on
slide 9 in the
                   quarterly slide deck accompanying your fiscal second quarter
2021 earnings call
                   as available on your website may provide more meaningful
information to
                   financial statement users.
               o   Similar to the Asset Management segment, Wholesale segment
revenue in Note
                   22 is also limited to non-interest revenue and net interest
revenue while in Item
                   5 on page 55 you provide revenue separately for Global
Markets and Investment
                   Banking with Global Markets being further broken down into
fixed income and
                   equity components in the narrative on page 56.
                 o
 Takumi Kitamura
Nomura Holdings, Inc.
February 16, 2021
Page 4

                   In Item 2.2(1) of your Quarterly Report for September 30,
2020 provided as
                   Exhibit 1 to Form 6-K filed on November 25, 2020 you provide
more granular
                   detail for Investment Banking and Asset Management fees; and
                Tell us how you considered the guidance in ASC 280-10-50-28
with regard to
              additional measures in the allocation of resources considering
net revenue from
              Americas represented 17.8% of total consolidated net revenue
whereas the related
              contribution to total consolidated income (loss) before income
taxes from Americas
              was only 3% and net revenue from Japan represented 71.5% of total
consolidated net
              revenue whereas the related contribution to total consolidated
income (loss) before
              income taxes from Japan was 94.7%.

       In closing, 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 Mark Brunhofer at 1-202-551-3638 or Michelle Miller at
1-202-551-
3368 with any questions.



FirstName LastNameTakumi Kitamura                            Sincerely,
Comapany NameNomura Holdings, Inc.
                                                             Division of
Corporation Finance
February 16, 2021 Page 4                                     Office of Finance
FirstName LastName