SEC Comment Letter for CBRE GROUP, INC. (CBRE) (CIK 0001138118) (CBRE) — Jun 12, 2017
CBRE GROUP, INC. (CBRE) (CIK 0001138118)
Date: June 12, 2017 · CIK: 0001138118 · Accession: 0000000000-17-020401
AI Filing Summary & Sentiment
Reasoning
Letter
Mail Stop 3233 June 12 , 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 reviewed your response to our May 10, 2017 comment letter 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
Segment Operations, page 40
Year Ended December 31, 2016 Compared to Year Ended December 31, 2015, page 42 Americas, page 42
1. Please refer to the response to comment 2. We note your statement that the recognition of the MSR asset at fair value results in a gain. In accordance with ASC Topic 860 -20- 25-4 separately recog nized servicing assets are included in proceeds from the sale of financial assets. As such, it appears the “gain from mortgage servicing rights” represents a gain on the sale of loans. Please clarify for us how you have considered the guidance in ASC Top ic 860 -20-25-4 and revise your disclosure accordingly. In your response, p lease provide us a sample journal entry reflecting how you record sale of the underlying loan and the removal of the receivable from your balance sheet.
Gil Borok CBRE Group, Inc. June 12 , 2017 Page 2
2. Please refer to the respo nse to comment 3 and confirm to us, if true, that the gain on MSR’s presented in the response are gross and that you did not experience any losses (e.g., servicing liabilities).
3. Please refer to the response to comment 3. It appears to us that ASC 2 30-10-45-21 applies to your fact pattern in that, while characterized as warehouse receivables, you are originating loans specifically for resale and, therefore, the related cash receipts and cash payments should be presented separately in the operating se ction of the statements of cash flow. Also, g iven the magnitude of the activity flowing through the warehouse receivable and payable accounts, we believe disaggregated information of this activity in the footnotes to the financial statements may provide a n investor an enhanced understanding of your loan warehouse operations . Please revise future filings accordingly.
We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any re view, 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.
Show Raw Text
Mail Stop 3233
June 12 , 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 reviewed your response to our May 10, 2017 comment letter 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
Segment Operations, page 40
Year Ended December 31, 2016 Compared to Year Ended December 31, 2015, page 42
Americas, page 42
1. Please refer to the response to comment 2. We note your statement that the recognition
of the MSR asset at fair value results in a gain. In accordance with ASC Topic 860 -20-
25-4 separately recog nized servicing assets are included in proceeds from the sale of
financial assets. As such, it appears the “gain from mortgage servicing rights” represents
a gain on the sale of loans. Please clarify for us how you have considered the guidance in
ASC Top ic 860 -20-25-4 and revise your disclosure accordingly. In your response, p lease
provide us a sample journal entry reflecting how you record sale of the underlying loan
and the removal of the receivable from your balance sheet.
Gil Borok
CBRE Group, Inc.
June 12 , 2017
Page 2
2. Please refer to the respo nse to comment 3 and confirm to us, if true, that the gain on
MSR’s presented in the response are gross and that you did not experience any losses
(e.g., servicing liabilities).
3. Please refer to the response to comment 3. It appears to us that ASC 2 30-10-45-21
applies to your fact pattern in that, while characterized as warehouse receivables, you are
originating loans specifically for resale and, therefore, the related cash receipts and cash
payments should be presented separately in the operating se ction of the statements of
cash flow. Also, g iven the magnitude of the activity flowing through the warehouse
receivable and payable accounts, we believe disaggregated information of this activity in
the footnotes to the financial statements may provide a n investor an enhanced
understanding of your loan warehouse operations . Please revise future filings
accordingly.
We remind you that the company and its management are responsible for the accuracy and
adequacy of their disclosures, notwithstanding any re view, 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