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December 12, 2023
Arthur Yu Chen
Chief Financial Officer
Futu Holdings Ltd
11/F, Bangkok Bank Building
No. 18 Bonham Strand W, Sheung Wan
Hong Kong S.A.R., People s Republic of China
Re: Futu Holdings Ltd
Form 20-F for
Fiscal Year Ended December 31, 2022
File No. 001-38820
Dear Arthur Yu Chen:
We have reviewed your September 28, 2023 response to our comment
letter and have the
following comments.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your response to this letter, we may have
additional comments. Unless
we note otherwise, any references to prior comments are to comments in
our September 18,
2023 letter.
Form 20-F for Fiscal Year Ended December 31, 2022
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent
Inspections, page 222
1. We note your response
to prior comment 1 that your subsidiaries in the United States,
Singapore, Australia,
Japan, Hong Kong, and mainland China are wholly owned and that
you are the primary
beneficiary of the VIEs and their subsidiaries. Please supplementally
clarify for us who
holds ownership interests in the VIEs and their subsidiaries.
2. We note your response
to prior comment 2 that you conducted inquiries and collected
questionnaires from the
members of the boards of directors and that nothing has come to
your attention
suggesting that any Director is an official of the Chinese Communist
Party. Please tell us
in more detail how you considered the profile of Mr. Shan Lu and
particularly his role
with the China United Network Communications Group Co.,
Ltd. Please also tell
us how you considered whether Mr. Lu has any current or prior
memberships on, or
affiliations with, committees of the Chinese Communist Party that are
Arthur Yu Chen
Futu Holdings Ltd
December 12, 2023
Page 2
not addressed in his biography on page 184 of your Form 20-F and whether
he is a
member of the Chinese Communist Party.
Please contact Jennifer Gowetski at 202-551-3401 or Andrew Mew at
202-551-3377 with
any other questions.
Sincerely,
FirstName LastNameArthur Yu Chen
Division of
Corporation Finance
Comapany NameFutu Holdings Ltd
Disclosure Review
Program
December 12, 2023 Page 2
cc: Will Cai
FirstName LastName