October 23, 2019

Karri Callahan
Chief Financial Officer
RE/MAX Holdings, Inc.
5075 South Syracuse Street
Denver, Co 80237

       Re: RE/MAX Holdings, Inc.
           Form 10-K for the year ended December 31, 2018
           Filed February 22, 2019
           Form 10-Q for the quarterly period ended June 30, 2019
           Filed August 2, 2019
           File No. 001-36101

Dear Ms. Callahan:

       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-Q for the quarterly period ended June 30, 2019

2. Summary of Significant Accounting Policies
Revenue Recognition, page 9

1.    We note your disclosure that you recognize an offsetting liability on the
balance sheet
      equal to marketing fund fees received. Please tell us your specific basis
for the timing and
      amounts of marketing costs you accrued. Please cite any relevant
accounting literature in
      your response.
 Karri Callahan
FirstNameHoldings, Inc. Callahan
RE/MAX LastNameKarri
Comapany NameRE/MAX Holdings, Inc.
October 23, 2019
October 23, 2019 Page 2
Page 2
FirstName LastName
6. Acquisitions, page 17

2.       Please explain to us why you allocated approximately $38 million to
other current
         liabilities as a result of your acquisition of the marketing funds. In
your response, clarify
         for us whether this liability is related to your policy for marketing
fund fees in which you
         recognize a liability and expense equal to marketing fund fees
received.
       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 Howard Efron, at (202) 551-3439 or Robert Telewicz, at
(202) 551-
3438 with any questions.



                                                                Sincerely,

                                                                Division of
Corporation Finance
                                                                Office of Real
Estate & Construction