SecProbe.io

April 28 , 2014

Via E-mail
Mr. Gil Borok
Chief Financial Officer
CBRE Group , Inc.
400 South Hope Street, 25th Floor
Los Angeles, California 90071

Re: CBRE Group , Inc.
 Form 10 -K for the year ended December 31, 201 3
Filed on March 3, 2014
File No. 001-32205

Dear Mr. Borok :

We have reviewed your filing an d have the following comment s.  In our comment s, we
may ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter via EDGAR within ten business days by provi ding the
requested information or by advising us when you will provide the requested response.   If you do
not believe our comment s apply to your facts and circumstan ces, please tell us why in your
response.

After reviewing the information you provide in response to these comment s, we may
have  additional comments.

Form 10 -K for the year ended December 31, 201 3

Item 7. Management’s Discussion and Analysis of Fina ncial Condition and Results of
Operations, page 35

Results of Operations, page 46

Year Ended December 31, 2013 Compared to Year Ended December 31, 2012, page 48

1) We note your disclosure that foreign currency translation resulted in a 73.4 million negative
impact on total consolidated revenue. In future periodic filings, please provide a more robust
discussion of the effects foreign currencies have on your operation s.  Specifically, please
disclose the currencies that have the greatest effect on your operations and quantify the
effects each had for each of the years presented. Provide a similar discussion within your
segment operations.

Mr. Gil Borok
CBRE Group , Inc.
 April 2 8, 2014
 Page 2

 Segment Operations, page 52

Global Investment Management, page 54

2) In an effort to provide more transparent disclosures regarding trends in investment
management fees, please revise your future periodic filings to include the following:

 Rollforward  of your Assets Under Management (AUM) for each period presented by
fund type to separately present gross inflows and outflows, distributions for a
realization event, and market appreciation/depreciation
 Discussion for the underlying reasons for changes in  AUM on a gross basis

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules re quire.   Since the company and its management are
in possession of all facts relating to a company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comment s, please provide  a writte n 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 a ny 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.

You may contact Shannon Sobotka, Staff Ac countant, at (202) 551 -3856 or me at (202) 551 -3629 if
you have questions .

Sincerely,

 /s/ Kevin Woody

Kevin Woody
Branch Chief