SEC Comment Letter for GreenTree Hospitality Group (GHG) — Mar 22, 2018
GreenTree Hospitality Group Ltd.
Date: March 22, 2018 · CIK: 0001724755 · Accession: 0000000000-18-008719
AI Filing Summary & Sentiment
File numbers found in text: 333-223261
Letter
Mail Stop 3233 March 20, 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 Registration Statement on Form F-1 Filed March 14, 2018 File No. 333-223261
Dear Ms. Geffner :
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 informatio n. 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.
Principal Shareholder, page 146
1. Footnote 2 states that GTI pledged 20% of your shares to Pudong Development Bank. Please confirm that Pudong Development Bank is not a beneficial owner of the pledged shares under Rule 13d -3(d)(3), or alternatively, revise to identify it as a beneficial owner of the pledged shares.
Jasmine Geffner GreenTree Hospitality Group Ltd. March 20, 2018 Page 2
You may contact 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 Attorne y, at (202) 551 -7150 or me at (202) 551 -3215 with any other questions.
Sincerely,
/s/ Kim McManus
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Mail Stop 3233 March 20, 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 Registration Statement on Form F-1 Filed March 14, 2018 File No. 333-223261 Dear Ms. Geffner : 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 informatio n. 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. Principal Shareholder, page 146 1. Footnote 2 states that GTI pledged 20% of your shares to Pudong Development Bank. Please confirm that Pudong Development Bank is not a beneficial owner of the pledged shares under Rule 13d -3(d)(3), or alternatively, revise to identify it as a beneficial owner of the pledged shares. Jasmine Geffner GreenTree Hospitality Group Ltd. March 20, 2018 Page 2 You may contact 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 Attorne y, at (202) 551 -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