SecProbe.io

June 12, 2018
Thomas S. Timko
Vice President, Global Business Solutions and Chief Accounting Officer
General Motors Company
300 Renaissance Center
Detroit, Michigan 48265
Re:General Motors Company
Form 10-K for the Year Ended December 31, 2017
Form 10-Q for the Quarter Ended March 31, 2018
File No. 001-34960
Dear Mr. Timko:
            We have limited our review of your filing to the financial statements and related
disclosures 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 business days by providing the requested
information or advise 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-Q for the Quarter Ended March 31, 2018
Notes to Condensed Consolidated Financial Statements
Note 2. Significant Accounting Policies
Revenue Recognition, page 7
1.Please tell us your consideration of disclosing any obligations for returns, refunds and
other similar obligations pursuant to ASC 606-10-50-20(d).
2.We note your disclosure that, beginning January 1, 2018, certain transfers to daily rental
companies are accounted for as sales and such transactions were previously accounted for
as operating leases.  We also note that transfers that occurred prior to January 1, 2018
continue to be accounted for as operating leases.  Please clarify if this accounting
treatment is due to the company’s adoption of ASC 606 and/or the prospective
modification of contract terms of such arrangements beginning in 2018.  Additionally, tell

 FirstName LastNameThomas S. Timko
 Comapany NameGeneral Motors Company
 June 12, 2018 Page 2
 FirstName LastName
Thomas S. Timko
General Motors Company
June 12, 2018
Page 2
us the facts and circumstances you considered for these transfers to determine they should
be recognized as sales in applying the guidance in ASC 606-10-55-66 through 78.  In your
response, tell us the amount of sales recognized and the impact to net income for these
transactions.  Finally, tell us your consideration to disclose significant judgments made for
determining which transactions classify as sales versus leases pursuant to ASC 235.
Item 2. Management's Discussion and Analysis of Financial Condition and Results of Operations
Non-GAAP Measures
Core adjusted automotive free cash flow, page 28
3.We note your disclosure of core adjusted automotive free cash flow, which appears to
exclude charges or liabilities that required cash settlement given that it excludes the free
cash flows of your autonomous vehicle operations. Please revise your disclosures to
ensure that your non-GAAP liquidity measures do not exclude charges or liabilities that
required or will require cash settlement. We refer you to Item 10(e)(1)(ii)(A) of
Regulation S-K.
Overview
Vehicle Sales, page 33
4.We note your table on page 33 summarizing total industry retail sales or estimated sales of
vehicles and your related competitive position by geographic region.  We also note that
you provide a breakout of the number of United States vehicles by cars, trucks and
crossovers but have not provided this information for any other region.  Please tell us your
consideration to disclose this information for your other geographic regions. In this
regard, we note your disclosure that GMI EBIT-Adjusted was impacted by the increased
sales of SUVs in the Middle East.
            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.
            You may contact Melissa Gilmore at (202) 551-3777 or Melissa Raminpour at (202) 551-
3379 with any questions.
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