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                              October 26, 2021

       David V  lez Osorno
       Chief Executive Officer
       Nu Holdings Ltd.
       Campbells Corporate Services Limited, Floor 4
       Willow House, Cricket Square, KY1-9010
       Grand Cayman, Cayman Islands

                                                        Re: Nu Holdings Ltd.
                                                            Amendment No. 2 to
Draft Registration Statement on Form F-1
                                                            Submitted October
8, 2021
                                                            CIK No. 0001691493

       Dear Mr. Osorno:

             We have reviewed your amended draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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 the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional
       comments.

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

       Dilution, page 97

   1.                                                   You disclose that the
number of shares outstanding at June 30, 2021 is 4,229,582,112 after
                                                        giving effect to the
share split which does not agree to the number of share outstanding on
                                                        page F-53. Please
revise your registration statement to ensure all share disclosures reflect
                                                        recent stock splits and
reconcile within. Refer to SAB Topic 4(C) - Change in Capital
                                                        Structure.
 David V  lez Osorno
FirstName LastNameDavid V  lez Osorno
Nu Holdings  Ltd.
Comapany
October 26,NameNu
            2021 Holdings Ltd.
October
Page 2 26, 2021 Page 2
FirstName LastName
Certain Relationships and Related Party Transactions
Equity Financings, page 263

2.       We note that the number of preferred shares you disclose that you have
issued related to
         your Series E, E-1, F, F-1, F-2, G and G-1 do not agree to the
preferred share detail in the
         consolidated financial statement footnotes on pages F-53 and F-139. We
also note these
         same differences in Item 7. Recent Sales of Unregistered Securities on
pages II-2 and II-
         3. Please revise your registration statement to ensure all share
disclosures reflect recent
         stock splits and reconcile within. Refer to SAB Topic 4(C) - Change in
Capital Structure.
        You may contact Michelle Miller at (202) 551-3368 or Sharon Blume at
(202) 551-
3474 if you have questions regarding comments on the financial statements and
related
matters. Please contact Tonya K. Aldave at (202) 551-3601 or Justin Dobbie at
(202) 551-
3469 with any other questions.



                                                               Sincerely,

                                                               Division of
Corporation Finance
                                                               Office of
Finance
cc:      Byron B. Rooney, Esq.