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                            October 20, 2020

       Michael Nessim
       Chief Executive Officer
       Kingswood Global Holdings Inc.
       17 Battery Place, Room 625
       New York, NY 10004

                                                        Re: Kingswood Global
Holdings Inc.
                                                            Registration
Statement on Form S-1
                                                            Filed October 13,
2020
                                                            File No. 333-249437

       Dear Mr. Nessim:

              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.

       Registration Statement on Form S-1

       Summary
       The Offering
       Founder shares, page 21

   1.                                                   Please revise to
clarify the vote required to approve the initial business combination. In
                                                        that regard, we note
that on pages 29 and 134 you disclose that if you seek stockholder
                                                        approval, you will
complete your initial business combination only if a majority of the
                                                        outstanding shares of
common stock are voted in favor of the initial business combination.
                                                        However, on page 99 you
disclose that if you seek stockholder approval, you will
                                                        complete your initial
business combination only if a majority of the outstanding shares of
                                                        common stock voted are
voted in favor of the initial business combination. In addition, we
                                                        note your revised
disclosure in response to prior comment 2 reflects that you would need
 Michael Nessim
FirstName
KingswoodLastNameMichael    Nessim
           Global Holdings Inc.
Comapany
October 20,NameKingswood
            2020           Global Holdings Inc.
October
Page 2 20, 2020 Page 2
FirstName LastName
         937,501, or 6.25%, of the 15,000,000 public shares sold in the
offering to be voted in
         favor of an initial business combination to approve an initial
business combination
         assuming a quorum is present at a stockholders' meeting. If such
disclosure assumes that
         only the minimum number of shares representing a quorum are present,
please make this
         clear in your disclosure.
Principal Stockholders, page 127

2.       Please revise to disclose the natural person or persons who exercise
voting or dispositive
         control over the shares beneficially owned by Pollen Street Capital
Limited. Refer to
         Exchange Act Rule 13d-3.
Description of Securities
Common Stock, page 133

3.       Although your prospectus cover page and disclosure on pages 21 and 128
state that only
         holders of Class B Common Stock will have the right to vote on the
appointment of
         directors prior to or in connection with the completion of your
initial business
         combination, we note you have removed related disclosure here, under
Founder Shares on
         page 135 and in Note 7 to your Financial Statements. Please advise or
revise. If holders
         of Class B Common Stock will have the right to vote on the appointment
of directors prior
         to or in connection with the completion of an initial business
combination, please also
         clarify that this is an exception to shareholders otherwise voting
together as a single class
         on all matters submitted to a vote of your shareholders.
General

4.       We note your revisions in response to prior comment 7. Please expand
your disclosure to
         discuss your and your sponsor's relationship with your financial
backers.
5.       Please ensure your registration statement is signed by a majority of
your board of
         directors. See Instruction 1 to the Instructions to the signatures
block of Form S-1.
        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.
 Michael Nessim
Kingswood Global Holdings Inc.
October 20, 2020
Page 3

       You may contact Brian McAllister, Staff Accountant, at (202) 551-3341 or
Craig Arakawa, Accounting Branch Chief, at (202) 551- 3650 if you have
questions regarding
comments on the financial statements and related matters. Please contact Karina
Dorin, Staff
Attorney, at (202) 551-3763 or Laura Nicholson, Special Counsel, at (202)
551-3584 with any
other questions.



                                                          Sincerely,
FirstName LastNameMichael Nessim
                                                          Division of
Corporation Finance
Comapany NameKingswood Global Holdings Inc.
                                                          Office of Energy &
Transportation
October 20, 2020 Page 3
cc:       Christopher Zochowski
FirstName LastName