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December 20, 2023
Paul A. Jacobson
Chief Financial Officer
General Motors Co
300 Renaissance Center
Detroit, Michigan 48265-3000
Re:General Motors Co
Form 10-K for the Year Ended December 31, 2022
Filed January 31, 2023
File No. 001-34960
Dear Paul A. Jacobson:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
            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.
Form 10-K for the Year Ended December 31, 2022
Management's Discussion and analysis of Financial Condition and Results of Operations
Non-GAAP Measures, page 25
1.We note your discussion of non-GAAP financial measures at the beginning of your
MD&A before any discussion of the comparable GAAP measures. Please revise future
filings to present and discuss the directly comparable GAAP measures with equal or
greater prominence than the non-GAAP measures. Refer to Item 10(e)(1)(i)(A) of
Regulation S-K and Question 102.10 of the Compliance and Disclosure Interpretations on
Non-GAAP Financial Measures. Your Form 8-K earnings releases should be similarly
revised.
Liquidity and Capital Resources, page 36
2.We note that you separately present and discuss operating, investing, and financing cash
flows at the Automotive, GM Financial, and Cruise segment levels without a
corresponding discussion at the consolidated level. Please tell us how your presentation

 FirstName LastNamePaul A. Jacobson
 Comapany NameGeneral Motors Co
 December 20, 2023 Page 2
 FirstName LastNamePaul A. Jacobson
General Motors Co
December 20, 2023
Page 2
complies with the requirement of Item 303(b) of Regulation S-K to discuss your business
as a whole with segment information provided as necessary.
Financial Statements
Consolidated Statements of Cash Flows, page 55
3.Please tell us the nature of all items included within the "Purchases of finance receivables,
net" and "Purchase of leased vehicles, net" line items and identify the parties from which
you purchase the applicable assets. In doing so, clarify if the balances include any material
offsetting amounts and how you determined net presentation was appropriate.
Notes to Consolidated Financial Statements
Note 2. Significant Accounting Policies
Revenue Recognition, page 57
4.We note your revenue recognition disclosures related to remarketing obligations at the top
of page 58. Please explain to us the specific nature of the arrangements and transactions
involved and the specific accounting guidance followed, including how you applied or
considered the repurchase agreement guidance in ASC 606-10-55-66 through -78. In
doing so, clarify if you account for any arrangements with daily rental companies as leases
or financing arrangements due to repurchase agreements and provide us with illustrative
journal entries to assist our understanding.
Inventories, page 59
5.As required by ASC 330-10-50-1, please disclose the basis of stating inventories, such as
FIFO, LIFO or estimated average cost. If LIFO or estimated average cost per unit is used,
provide the additional disclosures required by Rule 5-02(6)(b)-(c) of Regulation S-X.
Stock Incentive Plans, page 62
6.We note your disclosure that compensation cost is "recorded on stock issued to settle
awards based on the fair value of Cruise's common stock until such time that the stock has
been issued for more than six months." Please clarify what this statement means and how
it complies with ASC 718.
Note 3. Revenue, page 64
7.ASC 606-10-50-4(a) requires entities to disclose the amount of revenue recognized from
contracts with customers under ASC 606 separately from other sources of revenues.
Please revise your disclosures, as necessary, to provide distinctions between ASC 606 and
non-ASC 606 revenues.

 FirstName LastNamePaul A. Jacobson
 Comapany NameGeneral Motors Co
 December 20, 2023 Page 3
 FirstName LastName
Paul A. Jacobson
General Motors Co
December 20, 2023
Page 3
            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.
            Please contact Heather Clark at 202-551-3624 or Andrew Blume at 202-551-3254 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Manufacturing