April 2, 2025 Evangelos Perros Chief Financial Officer Pagaya Technologies Ltd. 90 Park Ave, 20th Floor New York, NY 10016 Re: Pagaya Technologies Ltd. Form 20-F for the Fiscal Year ended December 31, 2023 Filed March 8, 2024 File No. 001-41430 Dear Evangelos Perros: We have completed our review of your filing. 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. Sincerely, Division of Corporation Finance Office of Energy & Transportation