SecProbe.io

August 15, 2024
Glenn Sanford
Founder, Chief Executive Officer and Chair of the Board
eXp World Holdings, Inc.
2219 Rimland Drive, Suite 301
Bellingham, WA 98226
Re:eXp World Holdings, Inc.
Definitive Proxy Statement on Schedule 14A
Filed March 27, 2024
File No. 001-38493
Dear Glenn Sanford:
            We have limited our review of your most recent definitive proxy statement to those issues
we have addressed in our comment(s).
            Please respond to this letter by providing the requested information  and/or confirming that
you will revise your future proxy disclosures in accordance with  the topics discussed below . 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.
Definitive Proxy Statement on Schedule 14A
Pay Versus Performance, page 41
1.The Company-Selected Measure should, in your assessment, "represent the most
important financial performance measure (that is not otherwise required to be disclosed in
the table) used by [you] to link compensation actually paid to [your] named executive
officers, for the most recently completed fiscal year, to company performance.” See Item
402(v)(2)(vi) of Regulation S-K. It appears that the Company-Selected Measure data
provided in your pay versus performance table has been measured across more than one
fiscal year, since the measurement periods start and end in September, rather than
December. Please ensure that the quantified performance information regarding your
Company-Selected Measure is not measured over a multi-year period. Refer to Item
402(v)(2)(vi) of Regulation S-K and Regulation S-K Compliance and Disclosure
Interpretation 128D.11.

August 15, 2024
Page 2
2.We note disclosure in footnote 9 to your pay versus performance table that due to
administrative errors, you adjusted the Summary Compensation Table for some of your
NEOs for 2021 and 2022 and you overstated the “Compensation Actually Paid to PEO”
for 2021 and overstated the “Average Compensation Actually Paid to Non-PEO NEOs”
for 2022. We also note that you limited your footnote disclosure to the most recent fiscal
year, but you state you also provide such footnote disclosure for 2022 and 2021 in
footnotes 2 and 4 to your pay versus performance table. Regulation S-K Compliance and
Disclosure Interpretation 128D.03 contemplates omitting footnote disclosure for all years
other than the most recent fiscal year unless the prior years’ footnote disclosure would be
material to an investor’s understanding of the information reported in the pay versus
performance table for the most recent fiscal year, or of the relationship disclosure
provided under Item 402(v)(5) of Regulation S-K. Please tell us how you concluded that
you were not required to provide footnote disclosure for years other than the most recent
fiscal year in light of the revisions to your Summary Compensation Table and
compensation actually paid amounts for 2021 and 2022.
            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 Conlon Danberg at 202-551-4466 or Daniel Crawford at 202-551-7767
with any questions.
Sincerely,
Division of Corporation Finance
Disclosure Review Program
cc:Ali Nardali, Esq.