SEC Comment Letter for GreenTree Hospitality Group (GHG) — Jun 26, 2019
GreenTree Hospitality Group Ltd.
Date: June 26, 2019 · CIK: 0001724755 · Accession: 0000000000-19-010362
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File numbers found in text: 333-231504
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June 24, 2019
Alex S. Xu
Chairman and Chief Executive 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-3
Filed June 13, 2019
File No. 333-231504
Dear Mr. Xu:
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 May 24, 2019 letter.
Amendment No. 1 to Form F-3, Filed June 13, 2019
General
1.We note your response to comment 1, including the risk factors you propose to include in
future prospectus supplements. Please revise your disclosure in this prospectus to include
the proposed risk factors herein.
Incorporation of Documents by Reference, page 44
2.Please revise to incorporate by reference the Form 6-K furnished on May 28, 2019.
FirstName LastNameAlex S. Xu
Comapany NameGreenTree Hospitality Group Ltd.
June 24, 2019 Page 2
FirstName LastName
Alex S. Xu
GreenTree Hospitality Group Ltd.
June 24, 2019
Page 2
Please contact Sara von Althann, Staff Attorney, at (202) 551-3207 or Erin E.
Martin, Legal Branch Chief, at (202) 551-3391 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate and
Commodities