Correspondence 0001171843-23-007284 from Colliers International Group Inc. (CIGI) (CIK 0000913353) (CIGI)
Colliers International Group Inc. (CIGI) (CIK 0000913353)
Date: Nov. 27, 2023 · CIK: 0000913353 · Accession: 0001171843-23-007284
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File numbers found in text: 001-36898
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CORRESP 1 filename1.htm 1140 Bay Street, Suite 4000 Toronto, Ontario M5S 2B4 Canada Main: +1 416 960 9500 November 27, 2023 Division of Corporation Finance Office of Real Estate & Construction United States Securities and Exchange Commission Washington, DC 20549 RE: Letter for Colliers International Group Inc. (the “Company”) dated November 15, 2023 (File No. 001-36898) This letter is in response to your above-noted letter. Our response is keyed to the comment in your letter. Comment: Form 40-F for the Fiscal Year Ended December 31, 2022 Exhibit 2 Notes to Consolidated Financial Statements Note 4. Acquisitions, page 24 1. We note your disclosure that goodwill amounts recognized are primarily attributable to assembled workforces, synergies with existing operations, and future growth prospects. Please revise future filings to provide a more robust qualitative description about the synergies with existing operations and future growth prospects when discussing goodwill acquired. Reference is made to paragraph 805-30-50-1(a) of the Accounting Standards Codification. Response: The Company agrees to enhance its disclosure related to goodwill amounts recognized under ‘Note 4. Acquisitions’ in accordance with paragraph 805-30-50-1(a) of the Accounting Standards Codification in its future filings. To illustrate, we plan to include the following disclosure in our next Form 40-F filing for the year ending December 31, 2023 under ‘Note 4. Acquisitions’: “The primary factors contributing to goodwill acquired in the years ended December 31, 2023 and December 31, 2022 are assembled workforces, synergies with existing operations and future growth prospects. Specifically, the synergies in our acquisitions primarily relate to diversifying our client base and service offerings, cross-sell opportunities, increasing our market share, and geographic expansion. Future growth prospects in the acquired businesses are consistent with long-term growth trends in the commercial real estate services and asset management industries.” . . . . Sincerely, Christian Mayer Chief Financial Officer Colliers International Group Inc.