SEC Comment Letter for GreenTree Hospitality Group (GHG) — Feb 1, 2018
GreenTree Hospitality Group Ltd.
Date: Feb. 1, 2018 · CIK: 0001724755 · Accession: 0000000000-18-003654
AI Filing Summary & Sentiment
Letter
Mail Stop 3233 January 31, 2018 Via E -Mail Jasmine Geffner Chief Financial Officer GreenTree Hospitality Group Ltd. 2451 Hongqiao Road, Changning District Shanghai 200335 People’s Republic of China
Re: GreenTree Hospitality Group Ltd. Amendment No. 1 to Draft Registration Statement on Form F -1 Submitted January 16, 2017 CIK No. 0001724755
Dear Ms. Geffner :
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 response.
After reviewing the information you provide in re sponse to these comments and your amended draft registration statement or filed registration statement, we may have additional comments.
General
1. We note the graphics and pictures included in response to prior comment 1. Please confirm that you own and /or franchise and manage all properties shown.
Index to Consolidated Financial Statements, page F -1
2. We note your response to comment 18 and await the updating of your financial statements in accordance with Rule 3 -12(f) of Regulation S -X.
Jasmine Geffner GreenTree Hospitality Group Ltd. January 31, 2018 Page 2
You may conta ct Isaac Esquivel, Staff Accountant, at (202) 551 -3395 or Kristi Marrone, Staff Accountant at (202) 551 -3429 if you have questions regarding comments on the financial statements and related matters. Please contact Joshua Lobert , Staff Attorney, at (202) 5 51-7150 or me at (202) 551 -3215 with any other questions.
Sincerely,
/s/ Kim McManus
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Mail Stop 3233 January 31, 2018 Via E -Mail Jasmine Geffner Chief Financial Officer GreenTree Hospitality Group Ltd. 2451 Hongqiao Road, Changning District Shanghai 200335 People’s Republic of China Re: GreenTree Hospitality Group Ltd. Amendment No. 1 to Draft Registration Statement on Form F -1 Submitted January 16, 2017 CIK No. 0001724755 Dear Ms. Geffner : 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 response. After reviewing the information you provide in re sponse to these comments and your amended draft registration statement or filed registration statement, we may have additional comments. General 1. We note the graphics and pictures included in response to prior comment 1. Please confirm that you own and /or franchise and manage all properties shown. Index to Consolidated Financial Statements, page F -1 2. We note your response to comment 18 and await the updating of your financial statements in accordance with Rule 3 -12(f) of Regulation S -X. Jasmine Geffner GreenTree Hospitality Group Ltd. January 31, 2018 Page 2 You may conta ct Isaac Esquivel, Staff Accountant, at (202) 551 -3395 or Kristi Marrone, Staff Accountant at (202) 551 -3429 if you have questions regarding comments on the financial statements and related matters. Please contact Joshua Lobert , Staff Attorney, at (202) 5 51-7150 or me at (202) 551 -3215 with any other questions. Sincerely, /s/ Kim McManus Kim McManus Senior Attorney Office of Real Estate and Commodities cc: Chris Lin, Esq. Simpson Thacher & Bartlett