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                              October 3, 2023

       Ting Kin Cheung
       Chief Executive Officer
       Plutus Financial Group Limited
       8/F, 80 Gloucester Road
       Wan Chai, Hong Kong

                                                        Re: Plutus Financial
Group Limited
                                                            Amendment No. 6 to
                                                            Draft Registration
Statement on Form F-1
                                                            Submitted September
15, 2023
                                                            CIK No. 0001933021

       Dear Ting Kin Cheung:

            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.

       Amendment No. 6 to Draft Registration Statement on Form F-1

       Cover Page

   1.                                                   Please revise your
cover page and make corresponding changes elsewhere in the
                                                        prospectus to disclose
a fixed price at which the selling stockholders will offer and sell
                                                        shares until your
shares are listed on a national securities exchange or quoted on the
                                                        OTCQX or OTCQB at which
time they may be sold at prevailing market prices. Refer to
                                                        Item 501(b)(3) of
Regulation S-K. In addition, please clarify whether the primary offering
                                                        is conditioned upon
receiving approval to list your Ordinary Shares on the Nasdaq Capital
                                                        Market. In this regard,
we note your disclosure that "[t]here is no assurance . . . that the
                                                        Ordinary Shares of
Plutus Group will be trading on Nasdaq Capital Market."
   2.                                                   Refer to your response
to comment 2. Your revised disclosure on your cover page, in
 Ting Kin Cheung
FirstName   LastNameTing Kin Cheung
Plutus Financial Group Limited
Comapany
October     NamePlutus Financial Group Limited
         3, 2023
October
Page 2 3, 2023 Page 2
FirstName LastName
         your prospectus summary and in your risk factors section specifically
highlights the
         impact to your business if you cannot transfer cash out of Hong Kong
but does not
         similarly highlight the impact if you cannot transfer cash into Hong
Kong. Please revise
         to state here, in your prospectus summary and in your risk factors
section that there is no
         assurance that the PRC government will not intervene or impose
restrictions on your
         ability to transfer cash into China, including Hong Kong, and include
a discussion
         regarding the impact if you cannot transfer cash into Hong Kong. In
this regard, we note
         that on your cover page and in your prospectus summary you include a
cross reference to
         your risk factor that states "[t]here is no assurance that the PRC
government will not
         intervene or impose restrictions on [y]our ability to transfer cash
into or out of Hong
         Kong." Please include this risk in your Summary of Significant Risk
Factors section
         along with a cross-reference to the risk factor in your risk factors
section.
Margin Financing, page 4

3.       We note your response to bullet point four in comment 3. Your
disclosure on page 5
         indicates there are no financing or other related costs for the margin
lending business;
         however, the disclosures on page 26 indicate that the Company derives
the funding for its
         margin financing business from a variety of sources, including funding
secured from
         commercial banks, other licensed financial institutions and other
parties as well as
         financing generated from our business operations. The latter suggests
that there may, in
         fact, be financing or other costs related to margin lending. Please
revise to address or
         clarify this inconsistency.
Selling Stockholders, page 48

4.       Please revise your table on page 48 to show the percentage owned by
each selling
         stockholder prior to the completion of the offering.
Analysis of Items with Major Changes on the Consolidated Balance Sheets
Balances with related parties, page 72

5.       Please revise your disclosures to provide a more detailed and thorough
discussion of your
         relationship with Fund SPC and its subsidiaries. Your revisions should
address the
         following:
             Define and explain what you mean when you say that Plutus Asset
Management
                 holds management shares   .
             Discuss what services are provided by the Fund SPC and its
subsidiary entities, and
              how related revenue, expenses, receivable and payable amounts are
determined.
             Disclose payment terms for the SPC-related receivables and
payables.
             Explain whether you are required to fund the operating expenses of
the Fund SPC
              and / or its subsidiaries. If so, explain why this is the case;
if not, explain why you
              have settled such expenses on behalf of them to date.
             Address how you plan to pay amounts owed to Fund SPC and its
subsidiaries
              (HK$20,038,000), given the liquidity levels of the Company at
December 31, 2022.
 Ting Kin Cheung
Plutus Financial Group Limited
October 3, 2023
Page 3
Related Party Transactions, page 113

6.    Refer to your response to comment 14. Your disclosure on page 114 that
"[t]he amount
      due from Mr. Zhao was mainly resulted from the financial support provided
to the
      Company by Mr. Zhao" seems to contradict your disclosure that these are
amounts due
      from Mr. Zhao. Please revise to clarify this disclosure so that it is
clear that these are
      amounts due from Mr. Zhao. In addition, please revise to clarify as to
whether these
      amounts will be paid to you prior to the effectiveness of your
registration statement.
       Please contact Marc Thomas at 202-551-3452 or Cara Lubit at 202-551-5909
if you have
questions regarding comments on the financial statements and related matters.
Please contact
Sonia Bednarowski at 202-551-3666 or Jessica Livingston at 202-551-3448 with
any other
questions.



                                                            Sincerely,
FirstName LastNameTing Kin Cheung
                                                            Division of
Corporation Finance
Comapany NamePlutus Financial Group Limited
                                                            Office of Finance
October 3, 2023 Page 3
cc:       Joe Laxague, Esq.
FirstName LastName