SecProbe.io

April 30, 2019
Christopher T. Hatto
Controller and Chief Accounting Officer
General Motors Company
300 Renaissance Center
Detroit, Michigan 48265-3000
Re:General Motors Company
Form 10-K for the Fiscal Year Ended December 31, 2018
Filed February 6, 2019
File No. 001-34960
Dear Mr. Hatto:
            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-K for the Fiscal Year Ended December 31, 2018
Management's Discussion and Analysis of Financial Condition and Results of Operations
Liquidity and Capital Resources
Automotive Liquidity, page 31
1.Please consider providing a consolidated table of cash flows provided by (used in)
operating, investing and financing activities for each year presented as shown in the
statements of cash flows, or a discussion of consolidated amounts.  In this regard, we note
you present separate tables of Automotive cash flows, GM Cruise cash flows, and GM
Financial cash flows, without reconciling these individual tables to the consolidated
amounts shown in statements of cash flows.  Please revise or advise.

 FirstName LastNameChristopher T. Hatto
 Comapany NameGeneral Motors Company
 April 30, 2019 Page 2
 FirstName LastName
Christopher T. Hatto
General Motors Company
April 30, 2019
Page 2
Note 8. Equity in Net Assets of Nonconsolidated Affiliates, page 64
2.We note equity income from your nonconsolidated affiliates represented approximately
25.3% of your income before income taxes for the year ended December 31, 2018, and
more specifically, the equity income from the Automotive China joint ventures
represented 23.1% of the pre-tax income.  Please advise of the consideration given to
providing financial statements of your Automotive China equity method joint ventures
pursuant to Rule 3-09 of Regulation S-X.  In this regard, if any of these joint ventures
meet the significance criteria, audited financial statements would be required for fiscal
year end December 31, 2018 and unaudited financial statements could be provided for the
comparative prior years in which the equity method income was less than 20% of your
pre-tax income.  Please advise or revise as appropriate.

            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 Beverly Singleton at (202) 551-3328 or Claire Erlanger at (202) 551-
3301 with any questions.
Sincerely,
Division of Corporation Finance
Office of Transportation and Leisure