United States securities and exchange commission logo

                             March 26, 2021

       Dave Girouard
       Chief Executive Officer
       Upstart Holdings, Inc.
       2950 S. Delaware Street, Suite 300
       San Mateo, CA 94403

                                                        Re: Upstart Holdings,
                                                            Draft Registration
Statement on Form S-1
                                                            Submitted March 23,
                                                            CIK No. 0001647639

       Dear Mr. Girouard:

                                                        This is to advise you
that we do not intend to review your registration statement.

               We request that you publicly file your registration statement no
later than 48 hours prior
       to the requested effective date and time. Please refer to Rules 460 and
461 regarding requests for
       acceleration. 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 David
Lin at (202) 551-3552 with any questions.


                             Division of Corporation Finance

                             Office of Finance