November 12, 2019

Ren  Lacerte
Chief Executive Officer
Bill.com Holdings, Inc.
1810 Embarcadero Road
Palo Alto, California 94303

       Re: Bill.com Holdings, Inc.
           Amendment No. 2 to Draft Registration Statement on Form S-1
           Submitted November 1, 2019
           CIK 0001786352

Dear Mr. Lacerte:

       We have reviewed your amended draft registration statement and have the
following
comment. In our comment, we may ask you to provide us with information so we
may better
understand your disclosure.

       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 our 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 comment
and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless otherwise noted, where prior comments are referred to they
refer to our letter
dated October 25, 2019.

Draft Registration Statement on Form S-1

Consolidated Financial Statements
Consolidated Statements of Cash Flows, page F-8

1.     We note your response to prior comment 2. Please revise to present the
cash flows from
       the change in the customer fund deposits liability as a financing
activity.
 Ren  Lacerte
FirstName LastNameRen  Lacerte
Bill.com Holdings, Inc.
Comapany 12, 2019
November NameBill.com Holdings, Inc.
Page 2
November 12, 2019 Page 2
FirstName LastName
        You may contact Eiko Yaoita Pyles, Staff Accountant, at (202) 551-3587
or Christine
Dietz, Senior Staff Accountant, at (202) 551-3408 if you have questions
regarding comments on
the financial statements and related matters. Please contact Jeff Kauten, Staff
Attorney, at (202)
551-3447 or Kathleen Krebs, Special Counsel, at (202) 551-3350 with any other
questions.



                                                             Sincerely,

                                                             Division of
Corporation Finance
                                                             Office of
Technology
cc:      James D. Evans, Esq.