United States securities and exchange commission logo





                              August 4, 2023

       Yong Suk Cho
       Chief Executive Officer
       Lufax Holding Ltd
       Building No. 6
       Lane 2777, Jinxiu East Road
       Pudong New District, Shangha
       People   s Republic of China

                                                        Re: Lufax Holding Ltd
                                                            Form 20-F for
Fiscal Year December 31, 2022
                                                            File No. 001-39654

       Dear Yong Suk Cho:

              We have limited our review of your filing to the submission
and/or disclosures as
       required by Item 16I of Form 20-F 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.

                                                        After reviewing your
response to these comments, we may have additional comments.

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

       Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 257

   1.                                                   We note your statement
that you reviewed the Company   s register of members and public
                                                        filings made by its
shareholders in connection with your required submission under
                                                        paragraph (a). Please
supplementally describe any additional materials that were reviewed
                                                        and tell us whether you
relied upon any legal opinions or third party certifications such as
                                                        affidavits as the basis
for your submission. In your response, please provide a similarly
                                                        detailed discussion of
the materials reviewed and legal opinions or third party
                                                        certifications relied
upon in connection with the required disclosures under paragraphs
                                                        (b)(2) and (3).
   2.                                                   In order to clarify the
scope of your review, please supplementally describe the steps you
                                                        have taken to confirm
that none of the members of your board or the boards of your
                                                        consolidated foreign
operating entities are officials of the Chinese Communist Party. For
 Yong Suk Cho
Lufax Holding Ltd
August 4, 2023
Page 2
      instance, please tell us how the board members    current or prior
memberships on, or
      affiliations with, committees of the Chinese Communist Party factored
into your
      determination. In addition, please tell us whether you have relied upon
third party
      certifications such as affidavits as the basis for your disclosure.
3.    We note that your disclosures pursuant to Items 16I(b)(2), (b)(3), and
(b)(5) are provided
      for    Lufax Holding Ltd or the consolidated affiliated entities    or
solely for    Lufax
      Holding Ltd.    We also note that your list of principal subsidiaries and
consolidated
      affiliated entities in Exhibit 8.1 appears to indicate that you have
subsidiaries in Hong
      Kong and countries outside China that are not included in your VIEs.
Please note that
      Item 16I(b) requires that you provide disclosures for yourself and your
consolidated
      foreign operating entities, including variable interest entities or
similar structures.

             With respect to (b)(2), please supplementally clarify the
jurisdictions in which
           your consolidated foreign operating entities are organized or
incorporated and
           provide the percentage of your shares or the shares of your
consolidated operating
           entities owned by governmental entities in each foreign jurisdiction
in which you
           have consolidated operating entities in your supplemental response.
             With respect to (b)(3) and (b)(5), please provide the required
information for you and
           all of your consolidated foreign operating entities in your
supplemental response.

        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.

      Please contact Austin Pattan at (202) 551-6756 or Jennifer Gowetski at
(202) 551-
3401 with any questions.



                                                            Sincerely,
FirstName LastNameYong Suk Cho
                                                            Division of
Corporation Finance
Comapany NameLufax Holding Ltd
                                                            Disclosure Review
Program
August 4, 2023 Page 2
cc:       Haiping Li
FirstName LastName