SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 May 15, 2025

Emma E. Giamartino
Chief Financial Officer
CBRE Group, Inc.
2121 North Pearl Street
Suite 300
Dallas, TX 75201

 Re: CBRE Group, Inc.
 Form 10-K for the fiscal year ended December 31, 2024
 File No. 001-32205
Dear Emma E. Giamartino:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comments.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe a
comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the fiscal year ended December 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Non-GAAP Financial Measures, page 47

1. We note your adjustment for Non-cash depreciation and amortization
expense related
 to certain assets attributable to acquisitions to arrive at Core net
income attributable to
 CBRE Group, Inc., as adjusted. Please tell us and revise your filing to
clarify the
 nature of this adjustment, including how it was derived. Further, please
tell us and
 revise your filing to clarify why the exclusion of this expense provides
useful
 information to investors. Please refer to Item 10(e) of Regulation S-K.
This comment
 also applies to your presentation of this non-GAAP measure in your
earnings release.
2. We note that you deduct certain passed through costs to derive net
revenue, a non-
 GAAP financial measure that you use to evaluate the operating
performance of the
 Company and its segments. We note your disclosure that these costs are
largely
 associated with subcontracted vendor work performed for clients and is
passed
 May 15, 2025
Page 2

 through to the client generally with no margin. As such, it appears that
some of the
 passed through costs may have a profit margin. Please provide us with
more
 information regarding the nature and terms of contracts with passed
through costs that
 have a profit margin and contracts with passed through costs that do not
have a profit
 margin, including the terms of any fees earned by you under the
contracts. In your
 response, please tell us whether the terms of your contracts
specifically require the
 customer to reimburse you for amounts paid to subcontractors and include
an example
 of the contract terms in your response. In addition, please include an
explanation of
 how you considered Question 100.04 of the Compliance & Disclosure
Interpretation
 on Non-GAAP Financial Measures in determining the appropriateness of
this
 adjustment. This comment applies to your presentation of net revenue
throughout your
 Form 10-K and in your earnings release.
 In closing, we remind you 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.

 Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at
202-551-3295
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real
Estate & Construction
</TEXT>
</DOCUMENT>