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UPLOAD Filing

CBRE GROUP, INC.
Date: July 11, 2025 · CIK: 0001138118 · Accession: 0000000000-25-007305

Financial Reporting Regulatory Compliance Revenue Recognition

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File numbers found in text: 001-32205

Date
July 11, 2025
Author
Finance
Form
UPLOAD
Company
CBRE GROUP, INC.

Letter

Re: CBRE Group, Inc. Form 10-K for the fiscal year ended December 31, 2024 Response dated May 27, 2025 File No. 001-32205 Dear Emma E. Giamartino:

July 11, 2025

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

We have reviewed your May 27, 2025 response to our comment letter and have the following comment.

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. Unless we note otherwise, any references to prior comments are to comments in our May 15, 2025 letter.

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 response to prior comment 2. Please clarify for us if any contracts are based on a fixed fee or similar (e.g., based on square footage managed or occupied), such that pass through costs have implied profit margins. To the extent you determine that there is an implied profit margin, please explain to us how you considered Question 100.04 of the Compliance & Disclosure Interpretation on Non-GAAP Financial Measures in determining the appropriateness of this adjustment throughout your Form 10-K and in your earnings release. July 11, 2025 Page 2

Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at 202-551-3295 if you have questions regarding comments on the financial statements and related matters.

Sincerely,
Division of Corporation
Finance
Office of Real Estate &
Construction

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 July 11, 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
 Response dated May 27, 2025
 File No. 001-32205
Dear Emma E. Giamartino:

 We have reviewed your May 27, 2025 response to our comment letter and
have the
following comment.

 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.
Unless we note otherwise, any references to prior comments are to comments in
our May 15,
2025 letter.

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 response to prior comment 2. Please clarify for us if any
contracts are
 based on a fixed fee or similar (e.g., based on square footage managed
or occupied),
 such that pass through costs have implied profit margins. To the extent
you determine
 that there is an implied profit margin, please explain to us how you
considered
 Question 100.04 of the Compliance & Disclosure Interpretation on
Non-GAAP
 Financial Measures in determining the appropriateness of this adjustment
throughout
 your Form 10-K and in your earnings release.
 July 11, 2025
Page 2

 Please contact Peter McPhun at 202-551-3581 or Jennifer Monick at
202-551-3295 if
you have questions regarding comments on the financial statements and related
matters.

 Sincerely,

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