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                             June 14, 2023

       Zexiong Huang
       Chief Executive Officer
       Pintec Technology Holdings Ltd
       3rd Floor, No. 11 Building
       No. 109 Yard Tianjizhigu
       Jinghai 3rd Street, BDA, Beijing, 101111
       People   s Republic of China

                                                        Re: Pintec Technology
Holdings Ltd
                                                            Form 20-F for the
Year Ended December 31, 2022
                                                            Filed May 15, 2023
                                                            File No. 001-38712

       Dear Zexiong Huang:

              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 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 to these comments, we may have additional comments.

       Form 20-F for the Year Ended December 31, 2022

       Introduction, page 1

   1.                                                   Please revise your
definition of China to remove the exclusion of Hong Kong and Macau
                                                        from the definition.
       Item 3. Key Information, page 3

   2.                                                   Please revise to
include the diagram of your corporate organizational structure in the
                                                        forepart of the filing.
Also, include a footnote to your diagram, which identifies the VIE
                                                        shareholders, their
relationship to the company, if any, and their percentage ownership in
                                                        each entity.
 Zexiong Huang
FirstName  LastNameZexiong  Huang
Pintec Technology Holdings Ltd
Comapany
June       NamePintec Technology Holdings Ltd
     14, 2023
June 14,
Page 2 2023 Page 2
FirstName LastName
Financial Information Related to the VIE Structures, page 5

3.       Please address the following as it relates to your condensed
consolidating schedules:
             Present amounts due to/due from between the VIEs and the parent
company and the
             VIEs and the WFOE separately from any amounts due to/due from
between the
             parent, WFOE and their equity owned subsidiaries.
             Tell us in what line item you include the investment in equity
owned subsidiaries and
             net assets of the VIEs and revise to include each of these amounts
in separate line
             items clearly distinguishing the equity-owned investments from the
VIE contractual
             arrangements.
             Similarly, clarify where you have included any share of income
(loss) of the VIEs
             and revise to disclose such amounts in a separate line item to
avoid any implication
             that the VIE arrangements are similar to an equity method
investment.
             Present any revenue and costs and expenses related to service fees
paid by the VIEs
             to the WFOE and/or parent company separately from the other costs
and expenses of
             the VIEs.
             Revise the cash flow information as necessary based on revisions
requested in the
             above bullet points.
Item 4. Information on the Company
A. History and Development of the Company, page 69

4.       We note that On October 21, 2022, you confirmed that your Chairman of
the Board of
         Directors and major shareholder, Jun Dong, has been detained and "is
under custody of
         the relevant PRC government authority." Please tell us and revise to
significantly expand
         your disclosures related to this matter. At a minimum, your
disclosures should include the
         following:
             the reasons for Mr. Dong's detainment by PRC authorities;
             the dates of such detainment including whether he remains
detained;
             any further actions taken, or proposed, by the PRC authorities
relating to Mr. Dong
              and/or the company; and
             any known financial impact, or potential financial impact, on the
company resulting
              from Mr. Jun Dong's detainment
         Also, describe in reasonable detail, Mr. Dong's involvement in the
operations of the
         business in his capacity as Chairman and significant shareholder.
Explain how Mr.
         Dong has been able to fulfill his role and responsibilities as
Chairman during his
         detainment and explain how your operations have continued to be
"conducted in the
         ordinary course" during his detainment.
Item 19. Exhibits, page 188

5.       Please revise to file the Exclusive Business Cooperation Agreement
between Pintec
         (Beijing) Technology Co. Ltd and Beijing Xinshun Dingye Technology Co.
Ltd. Refer to
         paragraph 4 to Instructions as to Exhibits to Form 20-F.
 Zexiong Huang
Pintec Technology Holdings Ltd
June 14, 2023
Page 3
Note 2. Summary of significant accounting policies
(g) Cash and cash equivalents, page F-13

6.       Please provide us with a detailed breakdown of the items included in
your total cash and
         cash equivalents and ensure that at a minimum, you separately provide
the amounts held
         in cash, time deposits and any other type of deposit (e.g. money
market funds).
Technical service fees , page F-20

7.       We note that you consider the online credit assessment, referral
control service, risk
         control service and post-lending management services are not distinct
and, therefore, you
         concluded that these services are one performance obligation. Please
describe for us each
         of these services and explain how you determined that such services
are not distinct.
         Also, tell us the service period for such arrangements and revise to
disclose how you
         measure progress toward completion for the performance obligation.
Refer to ASC 606-
         10-25-19 through 21 and 50-18.
       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 David Edgar, Senior Staff Accountant, at (202) 551-3459
or Kathleen
Collins, Accounting Branch Chief, at (202) 551-3499 with any questions.



FirstName LastNameZexiong Huang                              Sincerely,
Comapany NamePintec Technology Holdings Ltd
                                                             Division of
Corporation Finance
June 14, 2023 Page 3                                         Office of
Technology
FirstName LastName