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                            June 7, 2023

       Arnaud Massenet
       Chief Executive Officer
       Aurora Acquisition Corp.
       20 North Audley Street
       London W1K 6LX, United Kingdom

                                                        Re: Aurora Acquisition
Corp.
                                                            Amendment No. 7 to
                                                            Registration
Statement on Form S-4
                                                            Filed May 11, 2023
                                                            File No. 333-258423

       Dear Arnaud Massenet:

             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
August 3, 2022 letter.

       Form S-4 Amendment No. 7 filed May 11, 2023

       General

   1.                                                   Please briefly explain
what you mean by "One-Day Mortgage" offering.
       Risk Factors
       We may not be able to grow our loan production business, page 89

   2.                                                   We note your response
to our prior comment 4 and reissue in part. Please revise the risk
                                                        factor title to remove
references to growth, because your loan volumes have recently
                                                        declined significantly.
 Arnaud Massenet
FirstName  LastNameArnaud Massenet
Aurora Acquisition Corp.
Comapany
June 7, 2023NameAurora Acquisition Corp.
June 7,
Page 2 2023 Page 2
FirstName LastName
We identified three ongoing material weaknesses in our internal control over
financial reporting,
page 106

3.       We note your disclosure on page 107 relating to a third material
weakness in your internal
         control over financial reporting as of December 31, 2022.
Specifically, we note that you
         identified a material error in your 409A valuation and certain
corresponding complex
         securities. Please clarify the nature of the material error in your
financial statements and
         whether there was a similar error or any impact to the December 31,
2021 financial
         statements.
Legal proceedings and governmental investigations in connection with the
Business
Combination, page 165

4.       This risk factor presents specific facts related to lawsuits and
investigations, including by
         the SEC   s Enforcement staff, alleging false of misleading statements
in the registration
         statement as originally filed. While lawsuits against parties to
merger transactions may be
         common, that statement improperly mitigates and detracts from the
specific risks
         addressed in this risk factor. Please remove the implication that the
issues raised in the
         disclosure here of this particular merger are    common    to other
merger transactions.
Nasdaq may delist our securities from trading on its exchange, page 175

5.       We note that one of the possible adverse consequences of Nasdaq
delisting your security
         from its exchange is that you Class A ordinary shares may become a
"penny stock."
         Please include a separate risk factor to discuss in greater detail the
extent to which your
         common stock may be characterized as a    penny stock    under Section
3(a)(51) of the
         Exchange Act and any risks you may face as a result. Please address
the requirements for
         broker-dealers to effect transactions in penny stocks under Section
15(h) of the Exchange
         Act and the specific legal remedies available to investors in penny
stocks if broker-dealers
         do not meet their obligations under the penny stock rules or if a
penny stock is sold in
         violation of the investor   s rights or otherwise in a fraudulent
manner. In addition, discuss
         how such requirements may adversely affect the market for your common
stock and
         increase transaction costs.
Resignation of Financial Advisors, page 227

6.       We note your response to our prior comment 9 and reissue in part. For
context, please
         disclose that there are similar circumstances in which the financial
institutions are named
         and that the resignations indicate those parties are not willing to
have the liability
         associated with such work in this transaction.
Better Overview, page 324

7.       We note your disclosure on page 325 that "[e]xcluding the severance
paid to terminated
         production employees, for the full year 2022, Better   s mortgage
production labor cost per
         unit was approximately $4,900 on average, compared to an annual
average
 Arnaud Massenet
FirstName  LastNameArnaud Massenet
Aurora Acquisition Corp.
Comapany
June 7, 2023NameAurora Acquisition Corp.
June 7,
Page 3 2023 Page 3
FirstName LastName
         of approximately $6,800 according to the MBA Quarterly Mortgage
Bankers Performance
         Reports." It appears that the quoted annual average according to the
MBA Quarterly
         Mortgage Bankers Performance Reports is calculated differently from
Better's mortgage
         production labor cost of $4,900. If so, please balance this disclosure
by also including
         your mortgage production labor cost per unit without excluding the
severance paid to
         terminated production employees or, in the alternative, consider
removing this statement.
Information about Better, page 324

8.       We note that in some sections of the prospectus you compare Better to
"other mortgage
         companies" and on page 121 to "other fintech companies." Please refer
consistently to
         your primary business of a mortgage company or provide us with support
that you are
         a fintech company.
Our Customer Acquisition Channels, page 333

9.       We note the disclosure here that your modular technology
infrastructure allows you to
         address your partners    requirements by combining existing solutions
and customizing
         functionality, and your disclosure on page 334 that your platform is
modular in nature and
         new products and partners can be added seamlessly using the same core
code and systems
         architecture. Please describe specific examples of when you added a
new product or new
         functionality for a client or partner in Tinman and provide support
for your disclosure on
         page 333 that Tinman's modular technology infrastructure
"substantially outperform[s] the
         traditionally long and operationally heavy enterprise integration
processes" or remove
         these statements.
Better's Management's Discussion and Analysis of Financial Condition and
Results of
Operations, page 348

10.      Please discuss and analyze your financial condition and changes in
your financial
         condition, including specifically discussing and analyzing material
changes to
         your balance sheet line items. Refer to Item 303 of Regulation S-K.
Results of Operations, page 362

11.      Please revise to include a discussion of changes in the components of
your total interest
         and other expense, net and their impact on your results of operations
for each period
         presented in the filing.
Cash Offer Program Revenue, page 364

12.      We note your discussion of changes in your cash offer program revenue.
Please revise to
         describe the extent to which such changes are attributable to changes
in price or volume.
         For example, consider quantifying the number of homes, average price
per home or
         information about the leasing of homes (for example, number of
months). Refer to Item
         303(b)(2)(iii) of Regulation S-K.
 Arnaud Massenet
Aurora Acquisition Corp.
June 7, 2023
Page 4
13.   We note your disclosure that you paused advertising on the Better Cash
Offer program.
      As it relates to your discussion of changes in marketing and advertising
expenses on page
      366, please revise to quantify marketing spend during each period
presented by program
      and/or product offering.
Retention Agreement with Kevin Ryan, page 392

14.   We note your disclosure here that you extended a forgivable loan of
$6,000,000, with an
      annual compounding interest rate of 3.5% to Mr. Ryan. It appears that the
loan will not be
      paid off until December 1, 2026. Please explain how you plan to comply
with Section
      402 of the Sarbanes-Oxley Act of 2002.
        You may contact Michael Henderson at 202-551-3364 or Robert Klein at
202-551-3847
if you have questions regarding comments on the financial statements and
related
matters. Please contact John Stickel at 202-551-3324 or Tonya Aldave at
202-551-3601 with
any other questions.



                                                          Sincerely,
FirstName LastNameArnaud Massenet
                                                          Division of
Corporation Finance
Comapany NameAurora Acquisition Corp.
                                                          Office of Finance
June 7, 2023 Page 4
cc:       Carl Marcellino, Esq.
FirstName LastName