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United States securities and exchange commission logo
October 24, 2022
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, 2021
Filed April 6, 2022
File No. 001-34936
Dear Qing Pan:
We have reviewed your September 28, 2022 response to our comment
letter and have the
following comment. We may ask you to provide us with information so we
may better
understand your disclosure.
Please respond 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. Unless we note otherwise, our references to prior comments are
to comments in our
September 15, 2022 letter.
Form 20-F for the fiscal year ended December 31, 2021 filed April 6,
2022
Financial Information Related to the VIEs, page 10
1. We note your response
to comment 3 and reissue the comment in part. With regard to
disclosure regarding
dividends or distributions that have been made by a subsidiary or
consolidated VIE to the
holding company, please revise to identify which entity or entities
made such transfer(s),
and the tax consequences to all entities involved in such transfer(s).
Qing Pan
FirstName LastNameQing
Noah Holdings Limited Pan
Comapany
October 24,NameNoah
2022 Holdings Limited
October
Page 2 24, 2022 Page 2
FirstName LastName
Please contact Christopher Wall at 202-551-4162 or David Gessert at
202-551-2326 with
any questions.
Sincerely,
Division of
Corporation Finance
Office of Finance