March 15, 2019

Tianhua Wu
Chief Executive Officer and Director
UP Fintech Holding LTD
18/F, Gandyvic Building, No. 1 Building,
No. 16 Taiyanggong Middle Road, Chaoyang District,
Beijing, 100020 PRC

       Re: UP Fintech Holding LTD
           Registration Statement on Form F-1
           Filed March 11, 2019
           File No. 333-229808

Dear Mr. Wu:

      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 March 8,
2019 letter.

Amendment No. 1 to Form F-1 Filed on March 11, 2019

Cover page

1.     The total amount of your offering, including the overallotment option,
calculated at the
       high end of your price range exceeds the maximum aggregate offering
amount shown in
       your fee table. Please revise to ensure that the maximum aggregate size
of the offering
       does not exceed the amount shown in the fee table.
Notes to the Consolidated Financial Statements
Note 10. Preferred Shares, page F-36

2.     We note your response to our comment 1 in your supplemental response
letter dated
 Tianhua Wu
UP Fintech Holding LTD
March 15, 2019
Page 2
      March 13, 2019. Please revise to disclose additional substantive terms of
the preferred
      share arrangements, such as consent and veto rights of the preferred
shareholders to
      prevent an IPO unless certain pre-money valuation and proceeds thresholds
are met. In
      addition, revise your Critical Accounting Policies, Judgments & Estimates
to disclose, in
      sufficient detail, the reasons why you believe it is not probable that
the convertible
      preferred shares will become redeemable, and thus, why you do not
recognize any
      accretion on the instruments.
Exhibits

3.    The legality opinion filed as Exhibit 5.1 appears to contemplate an
offering by the
      company and by selling shareholders. Please revise to provide a legality
opinion that is
      specific to this offering.
       You may contact Stephen Kim at 202-551-3291 or Robert Klein at
202-551-3847 if you
have questions regarding comments on the financial statements and related
matters. Please
contact Jessica Livingston at 202-551-3448 or Pam Long at 202-551-3765 with any
other
questions.



                                                           Sincerely,
FirstName LastNameTianhua Wu
                                                           Division of
Corporation Finance
Comapany NameUP Fintech Holding LTD
                                                           Office of Financial
Services
March 15, 2019 Page 2
cc:       Ke Geng
FirstName LastName