September 25, 2019

Daniel Mathewes
Executive Vice President and Chief Financial Officer
Hilton Grand Vacations Inc.
6355 MetroWest Boulevard
Suite 180
Orlando, FL 32835

       Re: Hilton Grand Vacations Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 28, 2019
           File No. 001-37794

Dear Mr. Mathewes:

       We have limited our review of your filing to the financial statements
and related
disclosures 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 10-K for the Fiscal Year Ended December 31, 2018

Management's Discussion and Analysis
Real Estate Sales and Financing Segment, page 55

1.    We note your reconciliation of sales of VOIs, net to contract sales.
Please clarify for us
      whether you consider contract sales to be a non-GAAP measure as defined
by Item 10(e)
      of Regulation S-K and the basis for your conclusion.
2019 Outlook, page 60

2.    We note your measure of adjusted free cash flow includes an adjustment
for net proceeds
      from securitization activity. Please explain the purpose of this non-GAAP
measure and
      the securitization activity adjustment. Your response should include a
discussion of how
      this measure is used by management and why you believe it provides useful
information
      to investors.
 Daniel Mathewes
Hilton Grand Vacations Inc.
September 25, 2019
Page 2
3.       Please expand your disclosure in future filings to include the
disclosure requirements of
         Item 10(e)(1)(i)(C) and (D) of Regulation S-K related to your measures
of Free Cash Flow
         and Adjusted Free Cash Flow.
Financial Statements
Note 5: Timeshare Financing Receivables, page 93

4.       Please revise your disclosure to include the carrying amount of
financing receivables
         pledged as collateral to secure your non-recourse revolving timeshare
receivable credit
         facility. Reference is made to ASC Topic 860-30-50-1A(b).
       In closing, 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 Babette Cooper, Staff Accountant, at 202-551-3396 or
Robert Telewicz,
Accounting Branch Chief, at 202-551-3438 with any questions.



                                                              Sincerely,
FirstName LastNameDaniel Mathewes
                                                              Division of
Corporation Finance
Comapany NameHilton Grand Vacations Inc.
                                                              Office of Real
Estate and
September 25, 2019 Page 2                                     Commodities
FirstName LastName