SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549-7010

       DIVISION OF
CORPORATION FINANCE

Mail Stop 3010
        May 3, 2010
 Brett White Chief Executive Officer CB Richard Ellis Group, Inc. 11150 Santa Monica Boulevard, Suite 1600 Los Angeles, California

Re: CB Richard Ellis Group, Inc.
 Form 10-K for the year ended 12/31/2009
Filed on 3/01/2010
File No. 001-32205

Dear Mr. White:

We have reviewed your filing and have the following comments.  Where
indicated, we think you should re vise your document in response to these comments.  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 explanation.  In
some of our comments, we may ask you to provi de us with information so we may better
understand your disclosure.  After reviewing th is information, we may 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 any other aspect of our review.  Feel free to call us at the telephone numbers listed at the end of this letter.
 FORM 10-K FOR THE YEAR ENDED DECEMBER 31, 2009
 General

1. We note that you have filed a proxy statement on April 19, 2010.  We also note
that inform
ation required by Part III of  your Form 10-K for fiscal year end
12/31/2009 is incorporated by reference fr om your proxy statement.  Please note
that we may have additional comments af ter we review your disclosure in the
proxy statement.

Brett White
CB Richard Ellis Group, Inc. May 3, 2010
Page 2

Item 7.  Management’s Discussion and Analysis of Financial Condition and Results of
Operations

Critical Accounting Policies, page 38
2. We note that you determined that no impairment of goodwill or other non-
am
ortizable intangible assets exis ted for 2009. Given the current economic
conditions and continued decline in your re venues, please provide us and disclose
in future filings how you considered thes e factors in determin ing that no further
impairment charge was necessary.
Liquidity and Capital Resources, page 56
3. In efforts to provide clarifying disclosure in light of your discussion throughout
the filing of various regulations and the corresponding im
pact of such regulations
on your business, please tell us if you r business has any material legal or
economic restrictions on the ability of the company’s subsidiaries to transfer
funds to the company.  If so, please confirm to us that you will provide disclosure
that complies in future filings.
 Significant Indebtedness, page 63

4. Please refer to you discussion of your funding arrangem ent with Fannie Mae
under the ASAP Program on pages 63 and 112. Please explain to us how you account for your commitments as it relates to repurchase of in terest in loans
previously sold, delivery of whole loan execution or securitization into mortgage
backed security. Please refer us to th e accounting literature you relied upon for
your accounting treatment.
 Consolidated Statements of Operations, page 75

5. Given the apparent significance of your equity loss from unconsolidated subsidiaries for 2009, please explain to us how you considered Rule 3-09 of
Regulation S-X as it r
elates to the require ments for separate financial statements
of equity method investees.
 Item 15. Exhibit and Financial St atement Schedules, page 148

 3.  Exhibits

 6. We note that exhibits 10.1(a), 10.1(b), 10.1(c), 10.1(e), and 10.1(h) only list and
do not include the exhibits and schedules listed in the tab
le of contents for each
respective agreement.  Because Item 601( b)(10) does not permit the omission of
information that is attached to a material contract, please file the complete

Brett White
CB Richard Ellis Group, Inc. May 3, 2010
Page 3

agreement in an amendment to your 10-K, in a Form 8-K, or as an exhibit to your
next periodic report.  Alternatively, please explain why the information was
omitted or why the agreements themselves are no longer material to investors.

Schedule III – Real Estate Investment s and Accumulated Depreciation, page 150

7. For each of your material projects identif ied und er this subheading, in future
filings, disclose the nature of your title t o, or other interest i n, such properties.
Please also revise your disclosure in th e Business section in future filings to
discuss the current status of  any material project in gr eater detail and to provide
any relevant real estate op erating data on a portfolio ba sis, i.e. average rents,
occupancy, lease expirations, tenant type, property type and geographic
diversification.  Please tell us  how you plan to comply.

******

 As appropriate, please amend your filing and respond to these comments within
10 business days or tell us when you will provid e 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 information.  Detailed co ver letters greatly faci litate our review.
Please understand that we may have addi tional comments after reviewing your
amendment and responses to our comments.    We urge all persons who are responsi ble for the accuracy an d adequacy of the
disclosure in the filing to be certain that the filing includes all in formation required under
the Securities Exchange Act of 1934 and th at they have provided all information
investors require for an informed invest ment 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
filing;
‚ staff comments or changes to disclosure  in response to staff comments do not
foreclose the Commission from taking any action with respect to the filing; 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.

Brett White
CB Richard Ellis Group, Inc. May 3, 2010
Page 4

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 filing or in response to our comments on your filing.

 You may contact Jorge Bonilla, Staff Accountant, at (202) 551-3414 or Cicely
Lamothe, Accounting Branch Chief, at (202) 551-3413 if you have questions regarding comments on the financial statements and related matters.  Please contact Jerard Gibson, Attorney-Advisor, at (202) 551-3473 or th e undersigned at (202) 551-3655 with any
other questions.
Sincerely,    Sonia Gupta Barros
 Special Counsel