United States securities and exchange commission logo





                              May 11, 2023

       Michael Tiedemann
       Chief Executive Officer
       AlTi Global, Inc.
       520 Madison Avenue, 21 st Floor
       New York, NY 10022

                                                        Re: AlTi Global, Inc.
                                                            Amendment No. 1 to
Registration Statement on Form S-1
                                                            Filed April 26,
2023
                                                            File No. 333-269448

       Dear Michael Tiedemann:

             We have reviewed your amended 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.
Unless we note
       otherwise, our references to prior comments are to comments in our
February 21, 2023 letter.

       Amendment No. 1 to Registration Statement on Form S-1

       General

   1.                                                   We note your response
to our prior comment 2 and reissue in part. We note your
                                                        disclosure that the
selling shareholders purchased the Class A Common Stock covered by
                                                        this prospectus for
prices "ranging from no consideration to $9.80." Please disclose
                                                        specific prices paid by
each group of the selling shareholders listed in the registration
                                                        statement, such as the
Sponsor, private placement investors, PIPE investors, and other
                                                        selling
securityholders. In this regard, for each of the securities being registered
for
                                                        resale, disclose on the
cover page the price the selling security paid for the securities or
                                                        units overlying such
securities, such as related to the Option Agreements.
   2.                                                   We note your response
to our prior comment 3 and reissue in part. Please update your
 Michael Tiedemann
AlTi Global, Inc.
May 11, 2023
Page 2
      disclosures throughout the filing and address areas that appear to need
updating or that
      present inconsistencies. Non-exclusive examples of areas where disclosure
should be
      updated are as follows:
          you disclose on page 67 "pro forma condensed combined financial
statements do not
           give affect to any anticipated operating efficiencies or cost
savings that may be
           associated with the business combination";
          you disclose that you "believe that following the Closing of the
Business
           Combination, the sources of liquidity discussed above will continue
to be sufficient to
           fund [your] working capital requirements" on pages 104 and 124-125;
          your disclosure that "following the Business Combination, you will be
subject to U.S.
           federal and state income taxes" on pages 106 and 126;
          your list of named executives "who will be named executive officers"
on page 210;
           and
          you disclose on page 50 that "future resales" of shares after the
consummation of the
           business combination may cause your market price to drop
significantly. This
           statement should be updated given that this prospectus is
facilitating those sales.
Prospectus Summary, page 1

3.    We note your response to our prior comment 5 and reissue in part. Please
disclose here
      the exercise price of the warrants compared to the market price of the
underlying
      securities and disclose the likelihood that warrant holders will not
exercise their warrants
      because the warrants are out of the money.

Management's Discussion and Analysis of Financial Condition and Results of
Operations
Liquidity and Capital Resources, page 87

4.    We note your response to our prior comment 10 and reissue in part. Please
revise your
      discussion to highlight the fact that the selling shareholders will be
able to sell all of
      their shares for so long as the registration statement of which this
prospectus forms a part
      is available for use.
       Please contact Tonya K. Aldave at (202) 551-3601 or Susan Block at (202)
551-3210
with any questions.



                                                             Sincerely,
FirstName LastNameMichael Tiedemann
                                                             Division of
Corporation Finance
Comapany NameAlTi Global, Inc.
                                                             Office of Finance
May 11, 2023 Page 2
cc:       Samantha Kirby, Esq.
FirstName LastName