United States securities and exchange commission logo January 27, 2023 Anthony Terry Executive Vice President and Chief Financial Officer Marriott Vacations Worldwide Corporation 9002 San Marco Court Orlando, FL 32819 Re: Marriott Vacations Worldwide Corporation Form 10-K for the fiscal year ended December 31, 2021 Filed March 1, 2022 File No. 001-35219 Dear Anthony Terry: 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 Real Estate & Construction cc: Kathy Pighini