April 3, 2019

Dinggui Yan
Chief Executive Officer
Jiayin Group Inc.
26th Floor, Building No. 1, Youyou Century Plaza
428 South Yanggao Road
Pudong New Area, Shanghai 200122
People's Republic of China

       Re: Jiayin Group Inc.
           Amendment No. 4 to
           Registration Statement on Form F-1
           Filed March 26, 2019
           File No. 333-228896

Dear Mr. Yan:

      We have reviewed your amended registration statement and have the
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
circumstances or do not believe an amendment is appropriate, please tell us why
in your

       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 15,
2019 letter.

Form F-1/A filed March 26, 2019

Risk Factors
We had limited experience managing our investor assurance program...., page 34

1.     You state that at your discretion you may use your working capital to
repay investors in
       order to maintain your reputation and your business and that results of
operation could be
       materially and adversely affected. Please disclose that during 2018, you
elected to pay
       RMB 1,079,932 in losses due to insufficient investor assurance program
 Dinggui Yan
FirstName LastNameDinggui Yan
Jiayin Group Inc.
Comapany NameJiayin Group Inc.
April 3, 2019
April 2 2019 Page 2
Page 3,
FirstName LastName
Management's Discussion and Analysis of Financial Condition and Results of
Selected Balance Sheet Items, page 115

2.       Please address year over year changes for Tax Payables, Payroll and
welfare payables,
         Refund liabilities and Accrued expenses and other current liabilities,
including when you
         expect to settle outstanding amounts due.
Liquidity and Capital Resources, page 119

3.       You state that you became one of the first individual lending
marketplaces to begin
         sharing credit information with Baihang Credit Co., Ltd., or Baihang
Credit, which
         integrates, saves and processes data collected from us and multiple
other companies and
         that you are able to report borrowers who are in default for more than
eight days to
         Baihang Credit. Disclose how are you are able to provide borrower
defaults after eight
         days considering that you do not track contract assets and accounts
receivable on an
         individual loan basis and do not monitor the aging of accounts
receivable and contract
         assets for each individual loan until maturity as disclosed in your
February 6, 2019
         response to us.
Investor Assurance Programs
Investor Assurance Progams Managed by Us, page 152

4.       Please disclose that during 2018, you elected to compensate investors
         1,079,932 for losses due to insufficient investor assurance program
Summary of Significant Accounting Policies
(o) Revenue Recognition, page F-20

5.       We note your response to comment 1 and your disclosure on page F-24 in
which you state
         that your allowance for uncollectible receivables methodology is
essentially the net
         expected accumulative loss rate used in determining the fair value of
guarantee liabilities.
         You also state on page 118, that since your payment terms are now
structured to collect
         service fees during the first two to six months of the loan inception
for current loan
         products, the risk of uncollectible amounts is significantly reduced.
Considering that
         your accounts receivable allowance provision of RMB 51.4 million in
relation to accounts
         receivable of RMB 1,517.3 million is significantly less than the net
expected accumulative
         loss rate used in determining the fair value of the guarantee
liabilities as disclosed on page
         F-17, please address the following:
           Disclose how your current accounts receivable allowance provision
rate aligns with
             your net expected accumulative loss rate and the basis for
recognizing such a lower
             provision, considering also the increase in the your accounts
receivable balance from
             RMB 189,993 at September 30, 2018 to RMB 364,863 at December 31,
2018 and the
             increase in the net expected accumulative loss rate for current
loan products from 11%
 Dinggui Yan
Jiayin Group Inc.
April 3, 2019
Page 3
          in 2017 to 11.3% in 2018;
          Disclose how your delinquency trends on page 96 impact your accounts
          allowance provision rate;
          Disaggregate your rollforwards of contract assets for each period
presented to
          separately disclose collections and write-off between current year
and prior periods;
          Disclose in your discussions on pages 115 - 118, consistent with your
response to
          comment 2 in your letter dated March 8, 2019, your assertion as to
the appropriateness
          of the allowance for uncollectible accounts for both accounts
receivable and contract
          assets; and
          Considering the termination of your investor assurance program in
April of 2018,
          clarify the historical loss experience utilized in the determination
of your allowance.
6.    We note your response to comment 2 and your revised disclosure on page
F-25. Please
      revise to clarify that the correction was an error in accordance with
7.    You state on page 104 that currently, you charge a substantial amount of
service fees on
      the same day when the first and second monthly repayments of principal
and interest are
      due and for loans facilitated prior to April 28, 2018, you also collect
remaining fees on a
      monthly basis but that you do not charge such monthly service fees for
loans facilitated
      after April 28, 2018. You also state on pages 115 and F-24, that you
began to record
      accounts receivable up to total fees collectible in the first six months
and contract assets
      for fees collectible in the subsequent months when recognizing revenue
from loan
      facilitation service subsequent to February 2018. Please reconcile these
      throughout the filing and specifically disclose when you charge and
recognize fees in
      accordance with the contract terms for each product for the periods
8.    Disclose in your accounting policy that you do not track contract assets
and accounts
      receivable on an individual loan basis and as such do not monitor the
aging of accounts
      receivable and contracts assets until loan maturity consistent with your
prior response and
      disclosure in the February 6, 2019 registration statement.
       You may contact Michelle Miller at 202-551-3368 or Marc Thomas at
202-551-3452 if
you have questions regarding comments on the financial statements and related
matters. Please
contact David Gessert at 202-551-2326 or Pam Long at 202-551-3765 with any
other questions.

FirstName LastNameDinggui Yan
                                                             Division of
Corporation Finance
Comapany NameJiayin Group Inc.
                                                             Office of
Financial Services
April 3, 2019 Page 3
cc:       Meng Ding, Esq.
FirstName LastName