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. 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. FirstName LastNameSteven F. DeGennaro Sincerely, Comapany NameMarcus & Millichap, Inc. Division of Corporation Finance November 17, 2022 Page 2 Office of Real Estate & Construction FirstName LastName