TEXT-EXTRACT 2 filename2.txt United States securities and exchange commission logo July 28, 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 reviewed your July 14, 2023 response to our comment letter 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. Unless we note otherwise, our references to prior comments are to comments in our June 14, 2023 letter. Form 20-F for the Fiscal Year Ended December 31, 2022 Financial Information Related to the VIE Structures, page 5 1. We note your proposed revised disclosures in response to prior comment 3. Please further revise your statements of operations to present a revenue amount that excludes any income from the VIE, along with a separate line item for WFOE and Other Subsidiaries revenues from sources other than the VIE. Similar revisions should be made to operating expenses and service fees paid to VIEs. In addition, explain why the VIE column does not include a separate line item reflecting an expense for the services fees paid to the WFOE and Other Subsidiaries, or revise. Zexiong Huang Pintec Technology Holdings Ltd July 28, 2023 Page 2 Item 4. Information on the Company A. History and Development of the Company, page 69 2. Please provide us with the following additional information as it relates to the proposed revised disclosures provided in your response to prior comment 4 and further revise your disclosures as necessary: Explain further what is meant by "certain economic disputes." Tell us when the Chairman was initially detained by the PRC authorities and when he was released from detainment. Describe what matters Mr. Xiaofeng Cui voted on in Mr. Jun Dong's absence and what "other matters" Mr. Jun Dong was able to address and how. Explain the basis for your assertion that Mr. Jun Dong's detainment has not caused, and will not result in, a material adverse impact on your business, results of operations or financial condition, particularly since you state that you have not received any updates from any PRC government authority or reliable resources or any inquiry or action from any government authority. Note 2. Summary of significant accounting policies (s) Revenue recognition Technical service fees, page F-20 3. We note your response to prior comment 7. Please explain further to us how technical service fees are determined each month. In this regard, you refer to loan volume, receipts from borrowers, etc. used in determining such fees. Clarify whether the loan volume is based on loans closed during the month or the outstanding balance of loans with the Financial Partner during the month and tell us how that factored into your analysis. Also, explain how receipts factor into the service fee and what the reference to "etc." includes. You may contact David Edgar, Senior Staff Accountant, at (202) 551-3459 or Kathleen Collins, Accounting Branch Chief, at (202) 551-3499 if you have any questions. Sincerely, FirstName LastNameZexiong Huang Division of Corporation Finance Comapany NamePintec Technology Holdings Ltd Office of Technology July 28, 2023 Page 2 cc: Yang Ge FirstName LastName