March 24, 2025

Christopher Britt
Chief Executive Officer
Chime Financial, Inc.
101 California Street, Suite 500
San Francisco, CA 94111

        Re: Chime Financial, Inc.
            Amendment No. 2 to Draft Registration Statement on Form S-1
            Submitted March 12, 2025
            CIK No. 0001795586
Dear Christopher Britt:

     We have reviewed your amended draft registration statement and have the
following
comments.

       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 a comment applies 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 this letter
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, any references to prior comments are to
comments in
our February 21, 2025 letter.

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

1.     We note your response to prior comment 1 and how you distinguish the
Banking and
       Switcher Survey and other surveys--which you state were not provided by
experts--
       from the FS Vector Report, for which you provide a consent. To similarly
       differentiate between the FS Vector Report and the surveys cited in your
registration
       statement, please revise the description of the Banking and Switcher
Survey and other
       surveys to indicate, as was explained in your response letter, that the
third parties gave
       you consolidated information "based on criteria or questions provided
by" you.
 March 24, 2025
Page 2

Glossary of Terms, page ii

2.     We note that you describe "MyPay" on page ii as a liquidity product that
allows your
       members to access up to $500 of their paycheck "for free within 24
hours, or instantly
       for a low fee." We also note that in the investor presentation dated
February 8, 2025
       you state that "MyPay instant transfer fee is $2 for any advance."
Please advise and, if
       applicable, revise your disclosure for consistency.
3.     We note your response to comment 4 from our letter dated January 7, 2025
       indicating that primary account relationships occur when members set up
"direct
       paycheck deposit" accounts, unless they fall under the alternative part
of the definition
       involving 15 or more purchases using their Chime cards. Please revise
the definition
       to clarify, if true, that a qualifying deposit involves direct paycheck
deposit.
Summary, page 2

4.     We note your response to prior comment 3. Please revise to identify
other financial
       technology competitors and, to the extent known, address the extent to
which the
       comparisons to traditional banks (e.g., 3 times and 5 times higher
cost-to-serve) are
       similar for your key financial technology competitors. In this regard,
we note based on
       your sales materials of "best-in-class" competitors that you also appear
to compete
       with Cash App, Nubank, PayPal, Klarna and Affirm.
Risk Factors
Fraudulent activity associated with our products, page 35

5.     We note your revised disclosure in the last sentence of the first
paragraph that you
       "have suffered and expect to continue to suffer losses from fraudulent
activities." If
       material, please quantify the losses or advise.
We are subject to laws and regulations covering anti-corruption, page 48

6.     We note your response to prior comment 10. It appears the statement that
"ChimeCore
       processes a portion of the payments, transfers, deposits, withdrawals,
and other
       financial transactions" and similar statements could be difficult to
understand in light
       of your other disclosure that Chime "does not currently engage as a
business in the
       transfer of funds" and "does not currently receive funds from or
transmit funds on
       behalf of members." Consistent with your response to prior comment 10,
please revise
       here, the definition of ChimeCore on page i and where appropriate to
clarify the
       difference between what you do in facilitating the processing of
payments as
       compared to what your operations do not involve (i.e., that they "...do
not involve
       receiving or transmitting funds...").

Business
Competition, page 167

7.     We note your response to prior comment 3. Please also revise to identify
other
       neobanks or similar companies as your competitors. In this regard, we
note that you
       also appear to compete with Nubank, Klarna and others based on the
test-the-waters
       materials.
 March 24, 2025
Page 3

Bank Partnerships, page 169

8.    We note your revised disclosure in this section that under the terms of
your bank
      partner agreements you earn interest on member deposits placed in the
deposit sweep
      programs, which you    recognize as revenue, net of the interest paid to
[y]our
      members.    If material, please quantify the approximate percentage of
interest paid to
      you and your members.
       Please contact Michael Henderson at 202-551-3364 or John Spitz at
202-551-3484 if
you have questions regarding comments on the financial statements and related
matters. Please contact Tonya Aldave at 202-551-3601 or James Lopez at
202-551-3536 with
any other questions.



                                                          Sincerely,

                                                          Division of
Corporation Finance
                                                          Office of Finance
cc:   Rezwan Pavri, Esq.