Investment Management Update in 2021

Investment Management Update:

The accounting firm of the SEC’s Investment Management Division regularly issues “Gear Chief Financial Officers” to assist registered investment firms, business development firms (BDCs), and their independent accountants with access to, auditing, reporting, or other disclosures. The activity. The letters provide interpretive guidelines for industry-specific SEC employees, and the Office of Accounting maintains an accounting bibliography (AMB) to contain them.

On March 30, the chief accountant removed or amended some old letters from his AMB due to changes in markets and regulations and added a new letter related to insurance products.

The Investment Management Division published the eight best financial statements from November 1994 to February 2001. Since then, team members have made their views known through other documents, including updates to IM policies, updates of IM information, accounting and disclosure of information, and CB issues. as well as the opinions of staff in correspondence with non-industrial groups such as the American Institute of Auditors and Accountants (AICPA), letters of denial, or other forgiveness.

The changes on March 30 are summarized below: one new letter, three withdrawn and five amended:

• IM-DCFO 1994-02 Valuation of some portfolio investments (1 November 1994) – Withdrawn on 8 September 2022.

• IM-DCFO 1995-11 Proforma Benefit Tables and Accumulation Tables (November 2, 1995) – Amended to reflect the impact of Rule 6-11 of the 1940 Act and to reflect employees’ perceptions of pro forma and congestion. a registration statement in which different possible outcomes can occur.

• IM-DCFO 1997-01 Foreign Pricing Considerations (7 November 1997) – Amended after 8 September 2022, date of compliance with Rule 2a-5 of the Tax Act 1940.

• IM-DCFO 1997-03 Designation of various assets (7 November 1997) – Withdrawal effective 19 August 2022, date of compliance with Rule 18f-4 of the 1940 Act.

• Expenditure on investment funds IM-DCFO 1997-06 – Dividend distribution (7 November 1997) – Amended to clarify individual views on specific closed-end fund expenses for dividend payments to preference shareholders.

• IM-DCFO Financial Statements 1998-07 (December 30, 1998) – Report.

• IM-DCFO 2001-06 file under section 488 of the Securities Act 1933 – amended as a result of changes in the Commission’s forms and regulations in May 2020. Section 488 of the 1933 Act requires, inter alia, that a registration declaration submitted by a public investment firm registered on Form N-14 automatically comes into force if certain criteria are met.

Combined statement of cash flows for IM-DCFO 2020-03 Advisers Act Rule 206 (4) -2 Compliance – Amended to make the type of factors to be considered by the team as an investment adviser or an adviser for partnership (or limited liability) extraordinary to assess enterprises or other types of compound investment vehicles) that are reviewed annually in accordance with rule 206 (4) -2 (b) (4); ) in terms of the Investment Advisers Act 1940 on certified consolidated financial statements.

Transfer of IM-DCFO 2021-01 Insurance Products to SAP from GAAP on Order or Request – Letter reminds underwriters of their obligations regarding offered periods and historical presentation.

Staff statement on cross-trading investment firms

SEC Investment Department officials issued a statement regarding the status of certain aspects of Rule 17a-7 of the 1940 Act, in particular the recent adoption of Rule 2a-5 of the 1940 Act (valuation rule), that the updated regulatory framework provides assessment practices (with the next compliance date) 1 In the statement, staff requested feedback on line 17a-7 within 30 days of placement. Several large entities, including the Investment Company Institute, the Asset Management Group of the Securities Industry Financial Markets Association (SIFMA), and several other market participants, sent comment letters in response to the statement.

In its current form, Rule 17a-7 allows registered investment firms to qualify as branches.

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