United States securities and exchange commission logo

                             April 28, 2021

       Michael Massaro
       Flywire Corporation
       141 Tremont St #10
       Boston, MA 02111

                                                        Re: Flywire Corporation
                                                            Amendment No. 1 to
Draft Registration Statement on Form S-1
                                                            Filed April 13,
                                                            CIK No. 0001580560

       Dear Mr. Massaro:

             We have reviewed your amended draft 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 providing the requested
information and either submitting
       an amended draft registration statement or publicly filing your
registration statement on
       EDGAR. 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

             After reviewing the information you provide in response to these
comments and your
       amended draft registration statement or filed registration statement, we
may have additional

       Draft Registration Statement submitted on April 13, 2021

       Business, page 102

   1.                                                   With respect to the
identification of customer identities on page 105 and elsewhere, please
                                                        confirm that you have
received consents to the references in your registration statement.
 Michael Massaro
FirstName   LastNameMichael Massaro
Flywire Corporation
April       NameFlywire Corporation
       28, 2021
April 228, 2021 Page 2
FirstName LastName
      Please contact Charlie Guidry at 202-551-3621 or Mara Ransom, Office
Chief, at 202-
551-3264 with any other questions.


                                                         Division of
Corporation Finance
                                                         Office of Trade &