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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

AI Filing Summary & Sentiment

File numbers found in text: 001-36898

Date
November 27, 2023
Author
Christian Mayer
Form
CORRESP
Company
Colliers International Group Inc. (CIGI) (CIK 0000913353)

Letter

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

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

Show Raw Text
CORRESP
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  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.