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SEC Response Letter

 BGC Partners, Inc.

499 Park Avenue

 New
York, NY 10022

 August 27, 2015

 United States
Securities and Exchange Commission

 Division of Corporation Finance

100 F Street, N.E.

 Washington D.C. 20549

Attention:
Jennifer Monick

Staff Accountant

Re:
BGC Partners, Inc.

Form 10-K For the Fiscal Year Ended December 31, 2014

Filed March 2, 2015

File No. 1-35591

 Dear Ms. Monick:

On behalf of BGC Partners, Inc. (the “Company”), we are writing in response to your comment letter, dated July 29, 2015,
relating to the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2014 filed on March 2, 2015 and Quarterly Report on Form 10-Q for the quarter ended March 31, 2015 filed on May 11, 2015.

For your convenience, the Company has repeated your comments in full, and the Company’s responses are consistent with the numbering of
the comments and headings used in your letter.

 The Company is requesting confidential treatment of the redacted portions of this letter
(indicated by asterisks [***]) in a separate letter to you, with a copy provided to the Office of Freedom of Information and Privacy Act Operations.

Form 10-K for the fiscal year ended December 31, 2014

Item 7A. Quantitative and Qualitative Disclosure About Market Risk

Foreign Currency Risk, page 125

1.
Please tell us what consideration you gave to providing a sensitivity analysis for each currency (e.g., British Pounds and Euro) that may have an individually significant impact on future earnings.

 United States Securities and Exchange Commission

Division of Corporation Finance

 August 27, 2015

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 Response #1

In consideration of your comments received on July 29, 2015, we advise the Staff that, in future filings, we will enhance our disclosure related to foreign currency risk to discuss the effects of exchange rates on
our results of operations. The following represents our proposed enhanced disclosure, using the six months ended June 30, 2015 for illustrative purposes:

Foreign Currency Risk

BGC Partners is exposed to risks associated with changes in foreign exchange rates. Changes in foreign exchange rates create
volatility in the U.S. Dollar equivalent of the Company’s revenues and expenses. In addition, changes in the remeasurement of BGC Partners’ foreign currency denominated financial assets and liabilities are recorded as part of its
results of operations and fluctuate with changes in foreign currency rates. BGC monitors the net exposure in foreign currencies on a daily basis and hedges its exposure as deemed appropriate with highly rated major financial institutions.

The majority of the Company’s foreign currency exposure is related to the U.S. Dollar versus the British Pound and
the Euro. While our international results of operations, as measured in U.S. Dollars, are subject to foreign exchange fluctuations, we do not consider the related risk to be material to our results of operations. For the financial assets and
liabilities denominated in the British Pound and Euro, including foreign currency hedge positions related to these currencies, we evaluated the effects of a 10% shift in exchange rates between those currencies and the U.S. Dollar, holding all
other assumptions constant. The analysis identified the worst case scenario as the Euro strengthening against the U.S. Dollar and the British Pound weakening against the U.S. Dollar. If as of June 30, 2015 the Euro had strengthened against
the U.S. Dollar by 10% and the British Pound had weakened against the U.S. Dollar by 10%, the currency movements would have had an aggregate negative impact on our net income of approximately $1.4 million.

20. Commitments, Contingencies and Guarantees

Employment, Competitor-Related and Other Litigation, page 168

2.
 We note that on January 13, 2015 you agreed to a settlement with Tullet Prebon plc wherein you paid $100 million in aggregate to resolve all ten
outstanding lawsuits. With respect to the settlement, please tell us how you have complied with ASC 450-20 in periodic filings prior to your Form 10-K for the fiscal year ended December 31, 2014. Specifically, tell us when the loss met the
probable and reasonably estimable criteria described in paragraph 2 of ASC 450-20-25. Additionally, tell us how you determined that the loss contingency was not at least reasonably

 United States Securities and Exchange Commission

Division of Corporation Finance

 August 27, 2015

Page 3 of 7

possible and that it was not necessary to disclose an estimate of the possible loss or range of loss in prior periodic filings in accordance with paragraph 4 of ASC 450-20-50. Your response
should include, but not be limited to, a discussion of the exact timeline of this settlement and the dates of your prior periodic filings.

Response #2

 In preparing its
quarterly financial statements, the Company evaluates each litigation, regulatory matter or other contingency to determine whether or not it is probable, reasonably possible or remote that a liability has been incurred, and, if it is probable,
whether a loss or range of loss can reasonably be estimated, under the provisions of ASC 450-20-50. Reserves are established or adjusted and further disclosure and estimates of potential loss are provided as information becomes available.

The Company’s policy is to include specific disclosure in notes to its financial statements about a litigation or regulatory matter if
there is at least a reasonable possibility that a material loss will be incurred. Consistent with ASC 450-20-50, the Company includes information about the nature of the matter and either an estimate of the potential loss or range of loss or, in the
event a reasonable estimate cannot be made, a statement that the Company is unable to estimate its potential liability or range of potential liability.

As described below, the Company disclosed and updated the disclosure related to the disputes with Tullett, a competitor of the Company, in the
Company’s periodic filings and recorded liabilities when potential losses became probable and reasonably estimable.

 United States Securities and Exchange Commission

Division of Corporation Finance

 August 27, 2015

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 As detailed on the enclosed timeline, the Company established reserves with respect to
potential liabilities related to the Tullett disputes in the applicable quarters which the Company believed were appropriate in light of the information available at the time. The Company reviewed these reserves on a quarterly basis throughout 2014.
In its periodic disclosures, the Company disclosed the amounts claimed in the Tullett matters and stated that it was unable to estimate a possible loss or range of loss in connection with specific matters beyond the current accrual and any other
amounts disclosed. It further noted in such filings that Company management believed that, based on then-currently available information, the final outcome of the pending Tullett disputes would not have a material adverse effect on the
Company’s consolidated financial statements and disclosures taken as a whole. The Company recorded liabilities in the appropriate periods when potential losses became probable and reasonably estimable. It was not until the Company reached the
final settlement with Tullett on January 13, 2015 that the Tullett disputes were settled and the full amount of the loss was determined.

Separate from the disputes with Tullett, the Company had commenced a tender offer to acquire all of the outstanding common stock of another of
its competitors, GFI Group Inc. (“GFI”), on October 22, 2014. In late December 2014 and early January 2015, the Company was aware of news reports and market intelligence regarding potential broker departures at GFI and potential
broker hiring by other industry competitors of the Company and GFI, including Tullett. At the same time, management of the Company understood that GFI was contemplating a potential settlement agreement regarding claims with another competitor that
would include various non-solicitation or non-hire provisions related to GFI’s brokers. In addition, an adverse judgment well in excess of the ultimate settlement amount, even if it were reversed on appeal (however probable), might have
affected the Company’s ability to complete the GFI tender offer (which management believed was becoming more likely). Further, a non-hire provision including GFI employees in a potential settlement became more useful to the Company in light of
the GFI tender offer. These factors contributed to management’s decision to settle all of the pending Tullett matters. A proposed Tullett settlement would resolve all ten matters, including the pending arbitrations and smaller state court
matters brought against individual managers and brokers, and contain a non-hire provision that would benefit the Company.

 In light of the
facts and circumstances, both in the Tullett matters and separately relating to the GFI tender offer, on January 13, 2015 the Company entered into a settlement agreement with Tullett to resolve all of the ten disputes. The settlement agreement
contained a one-year non-hire provision in which the Company and Tullett agreed not to hire the senior employees, including desk heads, of the other party and its subsidiaries. The non-hire provision specifically included employees of GFI in the
event that the Company closed on its proposed acquisition of GFI.

 United States Securities and Exchange Commission

Division of Corporation Finance

 August 27, 2015

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 Following the Tullett settlement, since the amount of the loss was finally and fully
determined prior to the Company issuing its Form 10-K for the year ended 2014, in that Form 10-K the Company disclosed the $100 million settlement amount and the fact that, as of December 31, 2014, the Company had accrued the settlement amount
and all related expenses in accordance with GAAP. On February 19, 2015, the Company entered into a tender offer agreement with GFI and closed on its acquisition of majority control of GFI on February 26, 2015.

We have attached as Exhibit A to this letter an exact timeline of the filing dates of the Company’s Form 10-Qs for 2014 and the
events surrounding the Tullett disputes and GFI tender offer.

 Form 10-Q for the quarterly period ended March 31, 2015

Notes to Condensed Consolidated Financial Statements

4. Acquisitions, page 16

3.
We note that you have recorded an intangible asset not subject to amortization in connection with the acquisition of GFI. Please tell us more about the trade name and the factors you considered in determining that it
has an indefinite life. In this regard, please tell us how you determined there are no legal, regulatory, contractual, competitive, economic, or other factors that limit the useful life of the trade name. See ASC 350-30-35-1 through -5.

 Response #3

 We
advise the Staff that the intangible asset not subject to amortization primarily consists of the trade name, GFI Group Inc. As noted in ASC 350-30-35-4, if no legal, regulatory, contractual, competitive, economic, or other factors limit the useful
life of an intangible asset to the reporting entity, the useful life of the asset shall be considered to be indefinite. ASC 350-30-35-4 further states that the useful life of an intangible asset is indefinite if that life extends beyond the
foreseeable horizon – that is, there is no foreseeable limit on the period of time over which it is expected to contribute to the cash flows of the reporting entity. GFI has built a strong reputation as a leading intermediary and provider of
trading technologies and support services to the global over-the-counter and listed markets, and provides brokerage and trade execution services to institutional customers in markets for a range of fixed income, financial, equity and commodity
instruments. The GFI trade name, which was established in 1987, is very well recognized in the industry and clearly adds value to the Company’s wholesale brokerage business.

 United States Securities and Exchange Commission

Division of Corporation Finance

 August 27, 2015

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As previously announced and disclosed in our prior filings, GFI is expected to remain a separately branded division of the Company for the foreseeable future. We further advise the Staff that we
have not identified any legal, regulatory or contractual limitations related to the trade name, GFI. GFI, in common with BGCP and the industry in general, has recovered from several economic downturns since GFI’s inception, which we believe is
a strong indicator that there are no foreseeable competitive, economic or other factors that would limit the useful life of the name. Based on these factors, we have concluded that there is no foreseeable limit on the period of time over which the
trade name is expected to contribute to our cash flows and have concluded that it has an indefinite life.

 20. Income Taxes, page 42

4.
Please tell us how you complied with paragraph 2 of ASC 740-30-50, or tell us how you determined it was not necessary to disclose the amount of additional tax that may be payable in the event that your undistributed
foreign pre-tax earnings are repatriated.

 Response #4

In consideration of your comment received July 29, 2015, we added the following disclosure to the note “20. Income Taxes” in our
fiscal year 2015 second quarter Form 10-Q filed August 10, 2015, and will include similar disclosure, as appropriate, in future filings:

As of June 30, 2015, the Company had $287.7 million of undistributed foreign pre-tax earnings; it is our intention to permanently reinvest
them in the Company’s foreign operations. It is not practicable to determine the amount of additional tax that may be payable in the event these earnings are repatriated due to the fluctuation of the relative ownership percentages of the
foreign subsidiaries between the Company and BGC Holdings, L.P.

 Item 2. Management’s Discussion and Analysis of Financial Condition and
Results of Operations

 Liquidity Analysis, page 67

5.
Please provide liquidity disclosures to discuss the potential tax impact associated with the repatriation of undistributed earnings of foreign subsidiaries in future periodic filings. In this regard, please disclose the
amount of cash that is currently held by your foreign subsidiaries and disclose the impact of repatriating the undistributed earnings of foreign subsidiaries. Please provide us with the disclosure you intend to include in future periodic filings.
Please refer to Item 303(A)(1) of Regulation S-K and Section IV of our Release 33-8350.

 United States Securities and Exchange Commission

Division of Corporation Finance

 August 27, 2015

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 Response #5

In consideration of your comment received on July 29, 2015, we advise the Staff that, in future filings, we will include disclosures
regarding the potential tax impact associated with the repatriation of undistributed earnings of foreign subsidiaries in our Liquidity Analysis. The following represents our proposed disclosure, using June 30, 2015 for illustrative purposes:

 As of June 30, 2015, the Company had $364.0 million of cash and cash equivalents, and included in this amount was $204.6 million
of cash and cash equivalents held by foreign subsidiaries. In addition, it is our intention to permanently reinvest undistributed foreign pre-tax earnings in the Company’s foreign operations. It is not practicable to determine the amount of
additional tax that may be payable in the event these earnings are repatriated due to the fluctuation of the relative ownership percentages of the foreign subsidiaries between the Company and BGC Holdings, L.P.

* * * *

 The Company hereby
acknowledges that (1) the Company is responsible for the adequacy and accuracy of the disclosure in the filing; (2) Staff comments or changes to disclosu