SEC Company Response from CBRE GROUP, INC. (CBRE) (CIK 0001138118) (CBRE) — Jun 15, 2006
CBRE GROUP, INC. (CBRE) (CIK 0001138118)
Date: June 15, 2006 · CIK: 0001138118 · Accession: 0001193125-06-130606
AI Filing Summary & Sentiment
Reasoning
Referenced dates: June 1, 2006
Letter
VIA EDGAR TRANSMISSION Securities and Exchange Commission Division of Corporate Finance Attention: Linda van Doorn Re: CB Richard Ellis Group, Inc. Form 10-K for the Fiscal Year Ended December 31, 2005 File No. 1-32205
Dear Ms. van Doorn:
Reference is made to the comments of the Staff of the Securities and Exchange Commission (the “SEC” or the “Staff”) with respect to the above referenced annual report on Form 10-K for the fiscal year ended December 31, 2005 (the “Form 10-K”) of CB Richard Ellis Group, Inc. (the “Company”) in the letter dated June 1, 2006, addressed to Kenneth J. Kay, Chief Financial Officer of the Company. Set forth below are the Staff’s comment and Company’s response.
Item 7 Management’s Discussion and Analysis of Financial Condition and Results of Operations
Segment Operations, page 42
1. We note that the Company has not included EBITDA on a segment basis in Note 20 to the financial statements and therefore the guidance in question 18 of the June 13, 2003 FAQ Regarding the Use of Non-GAAP Financial Measures is not applicable. If the Company continues to report EBITDA on a segment basis the Non-GAAP performance measure should be reconciled to net income as discussed in question 15 of the FAQ.
Company Response
The Company respectfully submits to the Staff that if it elects to continue to report EBITDA on a segment basis, it will reconcile it to net income in its future filings. If the Company determines that it is impractical to reconcile EBITDA to net income by segment, the Company will cease reporting EBITDA on a segment basis.
In the event you have any additional questions, please contact me directly at (310) 606-4700.
Sincerely,
/s/ Kenneth J. Kay
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CORRESP 1 filename1.htm SEC Response Letter Kenneth J. Kay Senior Executive Vice President Chief Financial Officer CB Richard Ellis Group, Inc. 100 N. Sepulveda Boulevard Suite 1050 El Segundo, CA 90245 310 606 4706 Tel 310 606 4701 Fax kenneth.kay@cbre.com www.cbre.com June 15, 2006 VIA EDGAR TRANSMISSION Securities and Exchange Commission Division of Corporate Finance 100 F Street, N.E. Washington, D.C. 20549 Attention: Linda van Doorn Re: CB Richard Ellis Group, Inc. Form 10-K for the Fiscal Year Ended December 31, 2005 File No. 1-32205 Dear Ms. van Doorn: Reference is made to the comments of the Staff of the Securities and Exchange Commission (the “SEC” or the “Staff”) with respect to the above referenced annual report on Form 10-K for the fiscal year ended December 31, 2005 (the “Form 10-K”) of CB Richard Ellis Group, Inc. (the “Company”) in the letter dated June 1, 2006, addressed to Kenneth J. Kay, Chief Financial Officer of the Company. Set forth below are the Staff’s comment and Company’s response. Item 7 Management’s Discussion and Analysis of Financial Condition and Results of Operations Segment Operations, page 42 1. We note that the Company has not included EBITDA on a segment basis in Note 20 to the financial statements and therefore the guidance in question 18 of the June 13, 2003 FAQ Regarding the Use of Non-GAAP Financial Measures is not applicable. If the Company continues to report EBITDA on a segment basis the Non-GAAP performance measure should be reconciled to net income as discussed in question 15 of the FAQ. Company Response The Company respectfully submits to the Staff that if it elects to continue to report EBITDA on a segment basis, it will reconcile it to net income in its future filings. If the Company determines that it is impractical to reconcile EBITDA to net income by segment, the Company will cease reporting EBITDA on a segment basis. In the event you have any additional questions, please contact me directly at (310) 606-4700. Sincerely, /s/ Kenneth J. Kay Kenneth J. Kay Chief Financial Officer