SEC Comment Letter for CBRE GROUP, INC. (CBRE) (CIK 0001138118) (CBRE) — Mar 19, 2008
CBRE GROUP, INC. (CBRE) (CIK 0001138118)
Date: March 19, 2008 · CIK: 0001138118 · Accession: 0000000000-08-014601
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-32205
Letter
Mail Stop 4561 March 19, 2008
Kenneth J. Kay Chief Financial Officer 11150 Santa Monica Boulevard, Suite 1600 Los Angeles, California 90025 Re: CB Richard Ellis Group Inc Form 8-K, Item 4.01 Filed March 18, 2008 File No. 001-32205 Dear Mr. Kay: We have reviewed your filing and have the following comment. Where indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your expl anation. In some of our comments, we may ask you to provide us in formation so we may better understand your disclosure. After reviewing this inform ation, we may or may not raise additional comments.
Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter.
Item 4.01, Form 8-K
Exhibit 16
1. We note the disclosure of a letter from your former independent accountant regarding its concurrence with the st atements made by you in a report dated March 18, 2008. Please amend your filing to disclose a letter from your former independent accountant regardi ng its concurrence or disagreement with the statements made by you in the current report dated March 12, 2008, concerning the resignation of your principal accountant.
* * * *
Kenneth J. Kay CB Richard Ellis Group Inc March 19, 2008 Page 2 As appropriate, amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendm ent to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please file your cover lett er on EDGAR. Please understand that we may have additional comments after reviewing your amendment and responses to our comments.
We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filings;
staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and
the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.
In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filings or in response to our comments on your filings. You may contact the unde rsigned at (202) 551-3472 if you have questions.
Sincerely,
Yolanda Crittendon Staff Accountant
Show Raw Text
Mail Stop 4561 March 19, 2008 Kenneth J. Kay Chief Financial Officer 11150 Santa Monica Boulevard, Suite 1600 Los Angeles, California 90025 Re: CB Richard Ellis Group Inc Form 8-K, Item 4.01 Filed March 18, 2008 File No. 001-32205 Dear Mr. Kay: We have reviewed your filing and have the following comment. Where indicated, we think you should revise your document in response to this comment. If you disagree, we will consider your explanation as to why our comment is inapplicable or a revision is unnecessary. Please be as deta iled as necessary in your expl anation. In some of our comments, we may ask you to provide us in formation so we may better understand your disclosure. After reviewing this inform ation, we may or may not raise additional comments. Please understand that the purpose of our re view process is to assist you in your compliance with the applicable disclosure requirements and to enhance the overall disclosure in your filing. We look forward to working with you in these respects. We welcome any questions you may have about our comments or on any other aspect of our review. Feel free to call us at the telephone numbers listed at the end of this letter. Item 4.01, Form 8-K Exhibit 16 1. We note the disclosure of a letter from your former independent accountant regarding its concurrence with the st atements made by you in a report dated March 18, 2008. Please amend your filing to disclose a letter from your former independent accountant regardi ng its concurrence or disagreement with the statements made by you in the current report dated March 12, 2008, concerning the resignation of your principal accountant. * * * * Kenneth J. Kay CB Richard Ellis Group Inc March 19, 2008 Page 2 As appropriate, amend your filing and respond to these comments within 10 business days or tell us when you will provide us with a response. You may wish to provide us with marked copies of the amendm ent to expedite our review. Please furnish a cover letter with your amendment that keys your responses to our comments and provides any requested supplemental information. Detailed cover letters greatly facilitate our review. Please file your cover lett er on EDGAR. Please understand that we may have additional comments after reviewing your amendment and responses to our comments. We urge all persons who are responsible for the accuracy and adequacy of the disclosure in the filings reviewed by the staff to be certain that they have provided all information investors require for an info rmed decision. Since the company and its management are in possession of all facts re lating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In connection with responding to our comments, please provide, in writing, a statement from the company acknowledging that: the company is responsible for the adequacy and accuracy of the disclosure in the filings; staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the filings; and the company may not assert staff comments as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. In addition, please be advise d that the Division of Enfo rcement has access to all information you provide to the staff of the Divi sion of Corporation Fi nance in our review of your filings or in response to our comments on your filings. You may contact the unde rsigned at (202) 551-3472 if you have questions. Sincerely, Yolanda Crittendon Staff Accountant