United States securities and exchange commission logo January 28, 2021 Qing Pan Chief Financial Officer Noah Holdings Limited Building 2 1687 Changyang Road Shanghai 200090, People s Republic of China Re: Noah Holdings Limited Form 20-F for the fiscal year ended December 31, 2019 Filed April 24, 2020 File No. 001-34936 Dear Mr. Pan: 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 Finance