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U.S. comment letter on investment companies' disclosures

Published on: Feb 17, 2015

Deloitte & Touche LLP comments on the FASB's proposed ASU, Disclosure About Investments in Other Investment Companies.

An excerpt from the comment letter is shown below:

We support the Board’s efforts to improve U.S. GAAP disclosures by increasing the transparency of investments by investment companies. As we noted in our February 15, 2012, comment letter, additional disclosures that increase the transparency of information about an investee fund would improve financial reporting. In addition, we support the Board’s efforts to align the disclosure requirements for investment companies regulated under the Investment Company Act of 1940 (the “1940 Act”) with those for investment companies not regulated under the 1940 Act.

We agree with the Board’s proposal to enhance disclosures about investment companies’ investments in other companies by requiring all investment companies to (1) disclose certain information about investments held by investee funds whose fair values exceed 5 percent of the reporting investment company’s net assets and (2) include the financial statements of a master fund with a feeder fund’s own financial statements in a master-feeder arrangement. However, as indicated in the appendix below, we have some concerns about the operability and auditability of the proposed disclosure requirements.

Full text of the comment letter is available below.


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