SEC Comment Letter for CBRE GROUP, INC. (CBRE) (CIK 0001138118) (CBRE) — Jul 1, 2013
CBRE GROUP, INC. (CBRE) (CIK 0001138118)
Date: July 1, 2013 · CIK: 0001138118 · Accession: 0000000000-13-035866
AI Filing Summary & Sentiment
Reasoning
Letter
July 1, 2013 Via E -mail Gil Borok Chief Financial Officer CBRE Group, Inc. 11150 Santa Monica Boulevard, Suite 1600 Los Angeles, CA 90025
Re: CBRE Group, Inc. Form 10 -K for fiscal y ear ended December 31, 2012 Filed March 1, 2013 File No. 1-32205
Dear Mr. Borok:
We have reviewed your response dated June 14 , 2013 an d have the following additional comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure.
Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and c ircumstances, please tell us why in your response.
After reviewing the information you provide in response to this comment, we may have additional comments.
Form 10 -K for fiscal year ended December 31, 201 2
Item 8. Financial Statements and Supplemen tary Data, 68
Notes to Consolidated Financial Statements, page 76
2. Significant Accounting Policies, page 76
Warehouse Receivables, page 85 1. We note your response to our prior comment three. Please tell us how you considered the loss sharing arrangemen t in your determination of whether or not a sale has occurred. Please refer to paragraph 46 of ASC 860 -10-55.
Gil Borok CBRE Group, Inc. July 1, 2013 Page 2
You may contact Mark Rakip, Staff Accountant at 202.551.3573 or the undersigned at 202.551.3295 if you have questions regarding the comment on t he financial statements and related matters.
Sincerely,
/s/ Jennifer Monick
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July 1, 2013 Via E -mail Gil Borok Chief Financial Officer CBRE Group, Inc. 11150 Santa Monica Boulevard, Suite 1600 Los Angeles, CA 90025 Re: CBRE Group, Inc. Form 10 -K for fiscal y ear ended December 31, 2012 Filed March 1, 2013 File No. 1-32205 Dear Mr. Borok: We have reviewed your response dated June 14 , 2013 an d have the following additional comment. In our comment , we may ask you to provide us with information so we may better understand your disclosure. Please respond to this letter within ten business days by providing the requested information or by advising us when you will provide the requested response. If you do not believe our comment appl ies to your facts and c ircumstances, please tell us why in your response. After reviewing the information you provide in response to this comment, we may have additional comments. Form 10 -K for fiscal year ended December 31, 201 2 Item 8. Financial Statements and Supplemen tary Data, 68 Notes to Consolidated Financial Statements, page 76 2. Significant Accounting Policies, page 76 Warehouse Receivables, page 85 1. We note your response to our prior comment three. Please tell us how you considered the loss sharing arrangemen t in your determination of whether or not a sale has occurred. Please refer to paragraph 46 of ASC 860 -10-55. Gil Borok CBRE Group, Inc. July 1, 2013 Page 2 You may contact Mark Rakip, Staff Accountant at 202.551.3573 or the undersigned at 202.551.3295 if you have questions regarding the comment on t he financial statements and related matters. Sincerely, /s/ Jennifer Monick Jennifer Monick Senior Staff Accountant