SEC Comment Letter for CBRE GROUP, INC. (CBRE) (CIK 0001138118) (CBRE) — Apr 23, 2015
CBRE GROUP, INC. (CBRE) (CIK 0001138118)
Date: April 23, 2015 · CIK: 0001138118 · Accession: 0000000000-15-022685
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 001-32205
Letter
April 2 3, 2015 Gil Borok Deputy Chief Financial Officer CBRE Group, Inc. 400 South Hope Street, 25th Floor Los Angeles, CA 90071
Re: CBRE Group, Inc. Form 10-K for Fiscal Year Ended December 31, 2014 Filed March 2, 2015 File No. 001-32205
Dear Mr. Borok :
We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure.
Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe ou r comments apply to your facts and circumstances, please tell us why in your response.
After reviewing your response to these comments, we may have additional comments.
Form 10 -K for Fiscal Period Ended December 31, 2014
Financial Stateme nts and Supplementary Data, page 70
Note 2. Significant Accounting Policies, page 78
Mortgage Servicing Rights, page 88
1. Please tell us and revise future filings to clarify your accounting policy for these assets at the lower of amortized cost or fair v alue by including the disclosure requirements of ASC 860-50-50-3 and 50 -4.
2. Please tell us and revise future filings to clarify how the recording of servicing assets at fair value resulted in net gains.
Gil Borok CBRE Group, Inc. April 2 3, 2014 Page 2
Note 4. Fair Value, page 92
3. Please provide us and revise the disclosures surrounding available for sale securities in future filings to include the requirements of ASC 320 -10-50-6 through 50 -8 regarding the impairment of securities.
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 require. Since the company and its management are in possession of all f acts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made.
In responding to our comments, please provide a written statement from the company acknowledging that:
the company is respon sible 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 s taff 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 Paul Cline at (202)551 -3851 or me at (202)551 -3629 with any questions.
Sincerely,
/s/ Kevin Woody
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April 2 3, 2015 Gil Borok Deputy Chief Financial Officer CBRE Group, Inc. 400 South Hope Street, 25th Floor Los Angeles, CA 90071 Re: CBRE Group, Inc. Form 10-K for Fiscal Year Ended December 31, 2014 Filed March 2, 2015 File No. 001-32205 Dear Mr. Borok : We have limited our review of your filing to the financial statements and related disclosures and have the following comments. In some of our comments, we may ask you to provide us with information so we may better understand your disclosure. Please respond to these comments within ten busine ss days by providing the requested information or advis e us as soon as possible when you will respond. If you do not believe ou r comments apply to your facts and circumstances, please tell us why in your response. After reviewing your response to these comments, we may have additional comments. Form 10 -K for Fiscal Period Ended December 31, 2014 Financial Stateme nts and Supplementary Data, page 70 Note 2. Significant Accounting Policies, page 78 Mortgage Servicing Rights, page 88 1. Please tell us and revise future filings to clarify your accounting policy for these assets at the lower of amortized cost or fair v alue by including the disclosure requirements of ASC 860-50-50-3 and 50 -4. 2. Please tell us and revise future filings to clarify how the recording of servicing assets at fair value resulted in net gains. Gil Borok CBRE Group, Inc. April 2 3, 2014 Page 2 Note 4. Fair Value, page 92 3. Please provide us and revise the disclosures surrounding available for sale securities in future filings to include the requirements of ASC 320 -10-50-6 through 50 -8 regarding the impairment of securities. 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 require. Since the company and its management are in possession of all f acts relating to a company’s disclosure, they are responsible for the accuracy and adequacy of the disclosures they have made. In responding to our comments, please provide a written statement from the company acknowledging that: the company is respon sible 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 s taff 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 Paul Cline at (202)551 -3851 or me at (202)551 -3629 with any questions. Sincerely, /s/ Kevin Woody Kevin Woody Accounting Branch Chief