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                                                            September 19, 2024

Christopher Lapointe
Chief Financial Officer
SoFi Technologies, Inc.
234 1st Street
San Francisco, California 94105

       Re: SoFi Technologies, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2023
           Form 10-Q for the Quarterly Period Ended June 30, 2024
           Form 8-K Filed July 30, 2024
           File No. 001-39606
Dear Christopher Lapointe:

       We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

       Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the Fiscal Period Ending December 31, 2023
Consolidated Results of Operations, page 98

1.     Please revise future filings to enhance your quantitative and
qualitative description of
       material changes from period to period, including where such changes
within a line item
       offset one another. Refer to Item 303 of Regulation S-K. Examples of
enhancements may
       include:
           narrative discussing changes over all periods presented. We note,
for example, that
           narrative disclosures at the top of page 103 and bottom of 108
appear to only include
           discussion of changes from 2021 to 2022.
           quantification of the key factors impacting period over period
changes, so that readers
           have context as to how much of the change is attributable to
different factors
           discussed and the extent of offsetting amounts.
           additional granularity, where applicable, to understand any
differences among
           material drivers or trends that apply to specific loan types. One
example might be
 September 19, 2024
Page 2

           enhanced discussion by loan type for the components that aggregate
into    loan
           origination, sales, and securitizations    within noninterest
income.
             when discussing multiple key drivers (e.g., for noninterest
income, noninterest
           expense, etc.), clear identification of the component line items to
which different
           drivers relate.
             enhanced explanation tying trends to underlying causes. As one
example only,
           disclosures on pages 102 and 109 note utilization and expansion of
lead generation
           channels but do not provide context as to type or nature of the
channels that have
           grown or been added.
Provision for Credit Losses
Analysis of Charge-offs, page 103

2.     We note your tabular disclosure on page 103 providing the net
charge-offs and ratio of net
       charge-offs to average loans by loan product for each period presented.
Please revise your
       disclosures, in future filings, to provide a discussion of the factors
that drove material
       changes in these numbers, or the related components, during all periods
presented. Refer
       to Item 1405(b) of Regulation S-K. Ensure your revised disclosure
includes, and
       quantifies where appropriate, consideration of the following:
           Clarification of what types of charge-offs are non-credit-related
and the differences, if
            any, between factors impacting credit and non-credit related
charge-off trends.
           Discussion of factors driving the changes in charge-off rates (e.g.,
delinquency rate
            trends, recovery amounts, etc.), by loan product.
Financial Services Segment, page 112

3.     We note your tabular disclosure on page 93 regarding Financial Services
products. Please
       revise future filings, here or elsewhere as appropriate, to more
fulsomely explain whether
       and how changes in these numbers relate to or impact revenue and expense
trends
       discussed within your Summary Results segment disclosures.
4.     We note your disclosure, such as on page 87, that your Financial
Services Segment
       primarily earns revenue from net interest income, referral fees,
interchange fees, and
       brokerage fees. The last three of these appear to be aggregated into
noninterest income in
       the table on page 112. In future filings, please include some
quantitative measure(s) to
       indicate the proportion of noninterest income attributable to these
different revenue
       streams.
5.     Exhibit 99.1 of your 8-K dated July 30, 2024 discloses that assets under
management have
       grown over 50% year-over-year. In future filings, including 10-Q and
10-K filings, please
       quantify assets under management for each period presented, and discuss
any material
       changes in levels or composition.


Critical Accounting Policies and Estimates
Goodwill, page 123

6.     For any reporting units that have recognized a goodwill impairment
charge or are deemed
 September 19, 2024
Page 3

       to be at risk of an impairment charge, please revise your disclosures in
future filings to
       quantify the amount of goodwill allocated to the reporting unit.
Interest Rate Risk, page 124

7.     We note your discussion of sensitivity analysis regarding interest rate
changes, including
       disclosure of certain assumptions incorporated into your analysis (e.g.,
market
       expectations of interest rates, contractual cash flows, etc.). In future
filings, please address
       the items below.
           Enhance your disclosures to discuss how any assumptions have changed
from period
           to period, including changes to data sources used or material
changes in judgements
           and determinations made by management as your modeling evolves.
           To the extent that management reviews sensitivity analyses for
additional
           hypothetical changes in interest rates (e.g., 50 or 200 basis point
changes in market
           interest rates, etc.), consider adding these other points to your
tabular disclosure.
           To the extent that your ALCO or senior management receives
information about and
           uses other metrics, such as economic value of equity (   EVE   ),
for purposes of
           managing or monitoring interest rate risk, consider expanding your
disclosure to
           include discussion of those other metrics and how management uses
them.
Consolidated Statements of Operations and Comprehensive Loss, page 132

8.     We note that you present Provision for credit loss within noninterest
expenses on the
       Consolidated Statements of Operations. We also note your disclosure on
page 122 that the
       Company became a bank holding company during 2022. Please tell us how
you
       considered presentation of your consolidated financial statements in
accordance with
       Article 9 of Regulation S-X.
Notes to Consolidated Financial Statements
Note 1. Organization, Summary of Significant accounting Policies
Financial Guarantees, page 140

9.     We note your disclosure, here and on page 171, that you entered into a
credit default swap
       related to your student loans that meets the definition of a financial
guarantee and is
       excluded from derivative accounting treatment. Please provide us with
your accounting
       analysis supporting your accounting for this credit default swap. The
response should
       include, but not be limited to, analysis addressing how this met the
definition of a
       financial guarantee, why it is excluded from derivative accounting
treatment, and how you
       determined that the insurance contract claim method should be applied.
Include specific
       references to authoritative guidance you used in reaching your
conclusions.
Note 7. Securitization and Variable Interest Entities, page 166

10.    We note your disclosure that you had investments in 22 nonconsolidated
VIEs as of
       December 31, 2023. In future filings, please enhance your footnote
disclosures to ensure
       they address all aspects of ASC 810-10-50-4, including quantification of
your maximum
       exposure to loss as a result of your involvement and a tabular
comparison of carrying
       amounts and classification of assets and liabilities in your statement
of financial position
       and maximum exposure to loss relating to your variable interests in the
VIEs.
 September 19, 2024
Page 4

Form 8-K Filed July 30, 2024
Exhibit 99.1
Non-GAAP Financial Measures, page 13

11.    We note your disclosure of adjusted EBITDA margin (pages 2, 7),
incremental adjusted
       EBITDA (page 2), segment-level contribution margin (pages 4, 6), and
incremental
       contribution profit margin (page 6). These appear to be non-GAAP
measures and
       therefore subject to the guidance in Regulation G and Item 10(e) of
Regulation S-K.
       Please revise future filings to explain how management uses these
measures, why
       management believes they are useful to investors, how they are
calculated, and to provide
       a reconciliation to the closest comparable GAAP measure. To the extent
that you
       reference such measures in 10-K or 10-Q filings, please make the same
future revisions.
       In this regard, we note your reference to segment-level contribution
margin on pages 85
       and 87 of your 2023 Form 10-K and on page 61 of your Form 10-Q for the
fiscal quarter
       ended June 30, 2024.
Form 10-Q for the Quarterly Fiscal Period Ended June 30, 2024
Note 4. Loans, page 16

12.    We note that senior secured loans appear to have grown to 80% of total
loans held for
       investment at amortized cost, 18.6% of total loans held for investment,
and 6.9% of total
       loans as of June 30, 2024. In future filings, please revise your
disclosures, in an
       appropriate location, to provide an expanded discussion of your senior
secured loans that
       more fully describes the borrower population, underlying collateral
characteristics, and
       typical duration of the loans.
       In closing, 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 Marc Thomas at 202-551-3452 or Cara Lubit at 202-551-5909
with any
questions.



                                                           Sincerely,

                                                           Division of
Corporation Finance
                                                           Office of Finance
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