SecProbe.io

Mail Stop 3233

May 10, 2017

Via E -mail
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
Filed March 1, 2017
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 our
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 Year Ended December 31, 2017

Management’s Discussion and Analysis of  Financial Condition and Results of Operations

Year Ended December 31, 2016 Compared to Year Ended December 31, 2015, page 37

1. Considering that you have consolidated revenues in excess of $13B for the year
ended December 31, 2016 and that; based on the information disclosed throughout
your filing, you have revenues from multiple lines of business, please tell us why you
do not provide disaggregated information of your revenues for each line of business.

 Segment Operations

Year Ended D ecember 31, 2016 Compared to Year Ended December 31, 2015
Americas, page 42

Gil Borok
CBRE Group, Inc.
May 10, 2017
Page 2

2. With respect to your investment in MSRs, please address the following:

 Please explain to us what you mean by the disclosure that gains from MSR’s are
initial ly recorded at fair value within revenue , clarifying what the gains
recognized on the origination and sale of mortgage loans represent.  Describe to
us the accounting process you follow in recognizing an MSR when it is separated
from a loan upon the sale of the loan.  In your response, explain to us how you
applied the guidance in ASC Topic 860 -20-25-4 with respect to your accounting
for MSRs.
 To the extent the “gain from mortgage servicing rights” represents a gain on the
sale of loans, please explain to us how you determined the gain should be
classified as a component of revenue.

3. We understand that you originate loans held for sale and that, based on your
disclosures; you have either a firm commitment to sell specific loans or a confirmed
forward trade co mmitment for the issuance and purchase of MBS that will be secured
by the loans. For each period presented in your financial statements, please tell us the
amount of loans originated for sale, the amount of the proceeds received on the loans
sold within th e periods and the net gain or loss on the sale of loans within the periods.
In addition, please clarify for us how your warehouse receivable activity is reflected
in your consolidated statements of cash flows and provide us with a reconciliation of
that a ctivity to line items in your consolidated statements of cash flows.  To the extent
this activity is shown on a net basis in your consolidated statements of cash flows,
please explain to us how you determined that presentation is appropriate.

We remind yo u that the company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

You may contact Paul Cline at (202)551 -3851 or the undersigned  at (202)551 -3438  with
any questions.

Sincerely,

 /s/ Robert F. Telewicz, Jr.

       Robert F. Telewicz, Jr.
       Accounting Branch Chief
       Office of Real Estate and
       Commodities