TEXT-EXTRACT 2 filename2.txt 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