SEC Comment Letter 0000000000-22-012490 to Marcus & Millichap, Inc. (MMI) (CIK 0001578732) (MMI)
Marcus & Millichap, Inc. (MMI) (CIK 0001578732)
Date: Nov. 17, 2022 · CIK: 0001578732 · Accession: 0000000000-22-012490
AI Filing Summary & Sentiment
File numbers found in text: 001-36155
Letter
United States securities and exchange commission logo November 17, 2022 Steven F. DeGennaro Chief Financial Officer Marcus & Millichap, Inc. 23975 Park Sorrento, Suite 400 Calabasas, CA 91302 Re:Marcus & Millichap, Inc. Form 10-K for the Fiscal Year Ended December 31, 2021 Filed March 1, 2022 File No. 001-36155 Dear Steven F. DeGennaro: We have limited our review of your filing to the financial statements and related disclosures and have the following comment. In our comment, we may ask you to provide us with information so we may better understand your disclosure. Please respond to the comment 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 comment applies to your facts and circumstances, please tell us why in your response. After reviewing your response to the comment, we may have additional comments. Form 10-K for the year ended December 31, 2021 Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations Material Cash Requirements, page 50 1.We note your disclosure on page 50 that you have a material cash requirement of $69,256,000 for deferred commissions payable. We further note your disclosure at the top of page F-27 indicates that deferred commissions payable is the aggregate of $110,769,000 and $31,697,000. Please tell us the nature of the difference between the amounts for deferred commissions payable on page 50 and page F-27. 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.
FirstName LastNameSteven F. DeGennaro Comapany NameMarcus & Millichap, Inc. November 17, 2022 Page 2 FirstName LastName Steven F. DeGennaro Marcus & Millichap, Inc. November 17, 2022 Page 2 You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Jennifer Monick, Assistant Chief Accountant at (202) 551-3295 with any questions. Sincerely, Division of Corporation Finance Office of Real Estate & Construction
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United States securities and exchange commission logo
November 17, 2022
Steven F. DeGennaro
Chief Financial Officer
Marcus & Millichap, Inc.
23975 Park Sorrento, Suite 400
Calabasas, CA 91302
Re:Marcus & Millichap, Inc.
Form 10-K for the Fiscal Year Ended December 31, 2021
Filed March 1, 2022
File No. 001-36155
Dear Steven F. DeGennaro:
We have limited our review of your filing to the financial statements and related
disclosures and have the following comment. In our comment, we may ask you to provide us
with information so we may better understand your disclosure.
Please respond to the comment 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
comment applies to your facts and circumstances, please tell us why in your response.
After reviewing your response to the comment, we may have additional comments.
Form 10-K for the year ended December 31, 2021
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Material Cash Requirements, page 50
1.We note your disclosure on page 50 that you have a material cash requirement
of $69,256,000 for deferred commissions payable. We further note your disclosure at the
top of page F-27 indicates that deferred commissions payable is the aggregate of
$110,769,000 and $31,697,000. Please tell us the nature of the difference between the
amounts for deferred commissions payable on page 50 and page F-27.
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.
FirstName LastNameSteven F. DeGennaro
Comapany NameMarcus & Millichap, Inc.
November 17, 2022 Page 2
FirstName LastName
Steven F. DeGennaro
Marcus & Millichap, Inc.
November 17, 2022
Page 2
You may contact Frank Knapp, Staff Accountant at (202) 551-3805 or Jennifer Monick,
Assistant Chief Accountant at (202) 551-3295 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction