December 18, 2019

Michele Allen
Chief Financial Officer
Wyndham Hotels & Resorts, Inc.
22 Sylvan Way
Parsippany, NJ 07054

       Re: Wyndham Hotels & Resorts, Inc.
           Form 10-K for the Fiscal Year Ended December 31, 2018
           Filed February 14, 2019
           Form 8-K filed October 29, 2019
           File No. 001-38432

Dear Ms. Allen:

       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 8-K filed October 29, 2019

Exhibit 99.1

1.    We note your inclusion of adjusted pretax income in Table 1. Please tell
us how you
      determined it was unnecessary to reconcile this measure to the most
directly comparable
      GAAP financial measure. Please refer to Item 10(e) of Regulation S-K.
2.    We note you provide 2019 outlook for adjusted EBITDA, adjusted pretax
income, and
      adjusted net income. Please tell us how you determined it was unnecessary
to provide the
      reconciliations required by Item 10(e)(1)(i)(B) of Regulation S-K. To the
extent you are
      relying on the "unreasonable efforts" exception in Item 10(e)(1)(i)(B),
please tell us how
      you determined it was unnecessary to disclose this fact and identify any
information that
      is unavailable and its probable significance. Please refer to Question
102.10 of the
      Division's Compliance and Disclosure Interpretations for Non-GAAP
financial
      measures.
 Michele Allen
Wyndham Hotels & Resorts, Inc.
December 18, 2019
Page 2

       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 Isaac Esquivel, Staff Accountant, at (202) 551-3395 or
Jennifer
Monick, Assistant Chief Accountant, at (202) 551-3295 with any questions.



FirstName LastNameMichele Allen                           Sincerely,
Comapany NameWyndham Hotels & Resorts, Inc.
                                                          Division of
Corporation Finance
December 18, 2019 Page 2                                  Office of Real Estate
& Construction
FirstName LastName