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                             October 21, 2020

       Gregory Dean Gibb
       Director and Chief Executive Officer
       Lufax Holding Ltd.
       No. 1333 Lujiazui Ring Road 15/F
       Pudong New District, Shanghai
       People   s Republic of China

                                                        Re: Lufax Holding Ltd.
                                                            Amendment No. 1 to
Registration Statement on Form F-1
                                                            Filed October 19,
2020
                                                            File No. 333-249366

       Dear Mr. Gibb:

             We have reviewed your amended 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 amending your registration
statement and providing the
       requested information. 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 any amendment to your registration statement and
the information you
       provide in response to these comments, we may have additional comments.
Unless we note
       otherwise, our references to prior comments are to comments in our
October 15, 2020 letter.

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

       Prospectus Summary
       Recent Developments, page 9

   1.                                                   We note your revised
disclosures on pages 9 and 10 relating to the recent C-Round
                                                        Restructuring
Convertible Notes stating that the transaction does not have a significant
                                                        dilutive impact. In
addition, we note from your pro forma diluted EPS calculation on page
                                                        98 that the pro forma
effect of conversion of Class C ordinary shares decreased compared
                                                        to your prior amendment
from 46,949,725 to 1,662,614 for the six months ended June 30,
                                                        2020. Please provide us
with your analysis and explanation supporting the statement that
                                                        the recent transaction
does not have a significant dilutive impact. In addition, tell us why
 Gregory Dean Gibb
Lufax Holding Ltd.
October 21, 2020
Page 2
         you do not include the pro forma effect of the conversion of the
convertible note into
         ordinary shares in your pro forma diluted EPS calculation, or revise
to show this impact.
Selected Consolidated Financial and Operating Data, page 97

2.       We note your response to comment 7 and revisions including pro forma
information
         giving effect to the transaction on pages 97, 98 and 99. Please
address the following:

                Revise to include a pro forma column and information in the
Summary
              Consolidated Financial and Operating Data beginning on page 17;
and

                Revise to provide greater clarity to each pro forma adjustment
reflected to each
              respective period. For example, disclose and explain the amount
and calculation of
              each pro forma adjustment made to cash at bank, liability line
items and equity line
              items for each period.

       You may contact Robert Klein, Staff Accountant, at (202) 551-3847 or
Marc Thomas,
Staff Accountant, at (202) 551-3452 if you have questions regarding comments on
the financial
statements and related matters. Please contact David Lin, Staff Attorney, at
(202) 551-3552 or
Michael Clampitt, Senior Counsel, at (202) 551-3434 with any other questions.



FirstName LastNameGregory Dean Gibb                            Sincerely,
Comapany NameLufax Holding Ltd.
                                                               Division of
Corporation Finance
October 21, 2020 Page 2                                        Office of
Finance
FirstName LastName