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CORRESP
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 CORRESP

 COMMERCIAL REAL ESTATE SERVICES

 CBRE Group, Inc.
 2121 N. Pearl Street

 Suite 300

 Dallas TX 75201

 www.cbre.com
 September 19, 2025
 Mr. Peter McPhun Ms. Jennifer Monick
 Office of Real Estate & Construction Division of
Corporation Finance Securities and Exchange Commission

 Re:
 CBRE Group, Inc.
 Form 10-K for the year ended December 31, 2024
 File No. 001-32205
 Dear Mr. McPhun and Ms. Monick: We are responding to
your comment letter dated September 5, 2025, to CBRE Group, Inc. (the “Company,” “CBRE,” “we,” “our” or “us”) with respect to the above referenced document.
 For ease of reference, we have repeated the comments of the Securities and Exchange Commission Staff (the “Staff”) in italics directly preceding
our responses. 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 our prior comment 1. Please address the following:

 •

 As it pertains to pass-through costs, please further clarify for us the nature and terms of your contracts
whose structures include pass-through with implicit pass-through net revenue cost-plus and cost-plus with GMP. In your response, please tell us how you determined these contract structures have an implicit margin, as opposed to an explicit
margin.

 •

 Regarding your contracts that are identified as explicit pass-through net revenue, please explain to us why
these contracts are categorized as having an explicit margin. In your response, please address your current characterization of such contracts as fixed priced contracts as it appears that they contain a
 mark-up on both fixed and variable costs. Also, please explain to us how you determined the explicit fees contractually earned on pass-through costs to estimate the margins for these contracts.

 2.
 In your response to our prior comment 1, you explain that to estimate an implicit margin on contracts quoted
with a fixed price or management fees that are charged to clients and may be derived as a percentage of total budgeted costs, you attributed a portion of the overall contract margin earned to the third-party pass-through costs incurred on the
contract by allocating the margin based on the percentage of third-party pass-through costs to total direct contract costs. Please address the following:

 •

 Please tell us how you define overall contract margin earned and total direct contract costs.

 •

 Please provide us with the company’s overall contract margin earned and total direct contract costs (if
it differs from the cost of revenue line item on your consolidated statements of operations) for the year ended December 31, 2024.

 •

 Please show us how the overall contract margin was allocated to calculate estimated margin by contract
structure. Response : The
Company acknowledges receipt of the Staff’s comments and informs the Staff that the Company will remove net revenue from its list of non-GAAP financial measures. This change will be reflected in the
Company’s earnings materials and future filings with the Securities and Exchange Commission, beginning with the Company’s third quarter 2025 reporting.
 Should you have any further questions regarding this matter, please feel free to contact me at (212) 984-8384.
 Sincerely, /s/ Emma Giamartino
 Emma Giamartino Chief Financial Officer
 CBRE Group, Inc.

 cc:
 William B. Brentani, Simpson Thacher & Bartlett LLP
 Kelli Schultz, Simpson Thacher & Bartlett LLP
 John Kemnitz, KPMG LLP