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September 11, 2023
Yiping Yang
Chief Financial Officer
GreenTree Hospitality Group Ltd.
1228 Zhongshan North Road, Putuo District
Shanghai 200065
People's Republic of China
Re:GreenTree Hospitality Group Ltd.
Form 20-F for the Year Ended December 31, 2022
Filed on April 28, 2023
File No. 001-38425
Dear Yiping Yang:
            We have reviewed your filing 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 these comments within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 20-F filed April 28, 2023
We face various legal and operational risks and uncertainties..., page 5
1.We note you face risks associated with regulatory approvals of offshore offerings, anti-
monopoly regulatory actions, cybersecurity and data privacy in China. Please state
affirmatively whether you have received all requisite permissions or approvals and
whether any permissions or approvals have been denied by the China Securities
Regulatory Commission (CSRC), Cyberspace Administration of China (CAC) or any
other governmental agency that is required to approve your subsidiaries’ operations in
China.  Please also describe the consequences to you and your investors if you or your
subsidiaries: (i) do not receive or maintain such permissions or approvals or (ii)
inadvertently conclude that such permissions or approvals are not required.
Uncertainties with respect to the Chinese legal system could adversely affect us, page 6

 FirstName LastNameYiping Yang
 Comapany NameGreenTree Hospitality Group Ltd.
 September 11, 2023 Page 2
 FirstName LastNameYiping Yang
GreenTree Hospitality Group Ltd.
September 11, 2023
Page 2
2.Please revise to clarify that the rules and regulations in China can change quickly with
little advance notice.
We may not pay further dividends to our public shareholders. . ., page 35
3.We note that you declared cash dividends in 2019 and 2021. Since you are a holding
company that relies principally on your operating subsidiaries in China for your cash
requirements, please quantify any cash flows and transfers of other assets by type that
have occurred between you and your subsidiaries, and direction of transfer.
Item 4. Information on the Company
C. Organizational Structure, page 85
4.Please provide a legible corporate structures diagram since your current diagram is too
small to be legible. Please ensure that the company’s parent and subsidiaries, including
name, country of incorporation or residence, proportion of ownership interest and, if
different, proportion of voting power held are clearly legible in your diagram.
Item 16I. Disclosure Regarding Foreign Jurisdictions that Prevent Inspections, page 128
5.Please supplementally describe any materials that were reviewed in connection with your
required submission under paragraph (a) and tell us whether you relied upon any legal
opinions or third party certifications such as affidavits as the basis for your submission. In
your response, please provide a similarly detailed discussion of the materials reviewed and
legal opinions or third party certifications relied upon in connection with the required
disclosures under paragraphs (b)(2) and (3).
6.In order to clarify the scope of your review, please supplementally describe the steps you
have taken to confirm that none of the members of your board or the boards of your
consolidated foreign operating entities are officials of the Chinese Communist Party. For
instance, please tell us how the board members’ current or prior memberships on, or
affiliations with, committees of the Chinese Communist Party factored into your
determination. In addition, please tell us whether you have relied upon third party
certifications such as affidavits as the basis for your disclosure.
7.We note that your disclosures pursuant to Item 16I(b) refers to “our company.” It is
unclear from the context of these disclosures whether these terms are meant to encompass
you and all of your consolidated foreign operating entities or whether in some instances
these terms refer solely to GreenTree Hospitality Group Ltd. Please note that Item 16I(b)
requires that you provide each disclosure for yourself and your consolidated foreign
operating entities, including variable interest entities or similar structures. To clarify this
matter, please provide the information required by each subsection of Item 16I(b) for you
and all of your consolidated foreign operating entities in your supplemental response.
4. Deconsolidations, page F-31

 FirstName LastNameYiping Yang
 Comapany NameGreenTree Hospitality Group Ltd.
 September 11, 2023 Page 3
 FirstName LastName
Yiping Yang
GreenTree Hospitality Group Ltd.
September 11, 2023
Page 3
8.We note your disclosure that starting in late May 2022, the group had been in dispute with
the minority shareholder of Argyle as to the performance of relevant transaction
documents and/or compliance with local laws and regulations by the minority shareholder
and that as a result, the group no longer has the power and ability to direct the relevant
activities of Argyle, and therefore, deconsolidated it beginning in June 2022. Please
further elaborate on the facts and circumstances that resulted in the group losing its ability
to control Argyle and consolidate it as a result of a minority shareholder's action or
inaction. In providing your response, please explain how the Company applied the
guidance in ASC 810-10-40-4 and ASC 810-10-55-4A to its facts and circumstances.
Finally, given the fact that the minority shareholder's action or inaction resulted in the
group's determination that it no longer controlled Argyle, please tell us how the Company
originally determined that it had a controlling financial interest in Argyle such that it
resulted in it consolidating Argyle. In that regard, please tell us how the Company
considered the variable interest and voting interest models in its application of ASC 810 in
reaching its conclusion.
6. Loans Receivable, Net, page F-34
9.We note that the provisions for the allowance for loans receivable was RMB
279 million  and RMB 118 million for fiscal years 2022 and 2021, respectively. Please tell
us more about the factors that led to the significant increase in the provision recognized
during fiscal year 2022. Please ensure that the Company’s MD&A disclosures fully
address the facts and circumstances that drove the change and whether the
disproportionate fluctuations and increase in trends are expected to recur. See Item
303(a)(3)(3)(i) and (ii) of Regulation S-K.
            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.
            You may contact Ameen Hamady at 202-551-3891 or Shannon Menjivar at 202-551-
3856 if you have questions regarding comments on the financial statements and related matters.
Contact Austin Pattan at (202) 551-6756 or Andrew Mew at (202) 551-3377 if you have any
questions about comments related to your status as a Commission-Identified Issuer during your
most recently completed fiscal year.  Please contact Kibum Park at 202-551-6836 or David
Link at 202-551-3356 with any other questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction