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                             September 18, 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 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 222

   1.                                                   We note your statement
that you reviewed your register of members and publicly
                                                        available documents
such as beneficial ownership reports on Schedules 13D or 13G 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
                                                        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
 Arthur Yu Chen
Futu Holdings Ltd
September 18, 2023
Page 2
         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    Futu Holdings Limited or the VIEs.    We also note that your
disclosure in Note 1 to
         your financial statements on page F-11 indicates that you have
consolidated foreign
         operating entities 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 disclose 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 information
required by (b)(3)
              and (b)(5) for you and all of your consolidated foreign operating
entities in your
              supplemental response.
4.       With respect to your disclosure pursuant to Item 16I(b)(5), we note
that you have included
         language that such disclosure is    to our knowledge.    Please
supplementally confirm
         without qualification, if true, that your articles and the articles of
your consolidated
         foreign operating entities do not contain wording from any charter of
the Chinese
         Communist Party.
        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 Jennifer Gowetski at 202-551-3401 or Andrew Mew at
202-551-3377 with
any other questions.



FirstName LastNameArthur Yu Chen                                Sincerely,
Comapany NameFutu Holdings Ltd
                                                                Division of
Corporation Finance
September 18, 2023 Page 2                                       Disclosure
Review Program
FirstName LastName