Mail Stop 4720

                                                                September 7,
2018



   Yue (Justin) Tang
   Chief Executive Officer and Chairman
   X Financial
   7-8F, Block A, Aerospace Science and Technology Plaza
   No. 168, Haide Third Avenue, Nanshan District
   Shenzhen, 518067, the People's Republic of China

          Re:    X Financial
                 Registration Statement on Form F-1
                 Filed August 28, 2018
                 File No. 333-227065

   Dear Mr. Tang:

          We have reviewed your 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.

   General

   1.     We note that Section 7.7 of the Form of Deposit Agreement (Exhibit
4.3) contains an
          irrevocable waiver of jury trial. Please revise your description of
American Depositary
          Shares to disclose this provision and to state that such a provision
may limit a
          shareholder's ability to bring a claim in a manner that it finds
favorable for disputes with
          the company and its directors, officers or other employees. Please
also add a separately
          captioned risk factor addressing the impact of your jury trial waiver
provision on
          investors.
 Yue (Justin) Tang
X Financial
September 7, 2018
Page 2

Summary of Significant Accounting Policies

Revenue Recognition, page F-16

2.     We note your response to comment 2. Please revise to label the allowance
for doubtful
       accounts of RMB 8,099,152 and RMB 175,799,647 as of December 31, 2016
and 2017,
       respectively, parenthetically on the face of the consolidated balance
sheets "as restated".

        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.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

       You may contact Michelle Miller at (202) 551-3368 or David Irving at
(202) 551-3321 if
you have questions regarding comments on the financial statements and related
matters. Please
contact David Gessert at (202) 551-2326 or me at (202) 551-3391 with any other
questions.

                                                             Sincerely,

                                                             /s/ Era Anagnosti

                                                             for Michael
Clampitt
                                                             Senior Counsel
                                                             Office of
Financial Services

cc:    Li He, Esq.