October 29, 2020
On October 23, 2020, the staff of the SEC Chief Accountant’s Office of the Division of Investment Management (Staff) issued its latest industry comment letters (Dear CFO Letters) directed to chief financial officers and independent public accountants of funds and business development companies (BDCs) regarding accounting- and auditing-related disclosure matters. The Staff announced in November 2019 that it was reviving the practice of issuing Dear CFO Letters, which as of that date the Staff had not issued since February 2001. The rescinded, modified or new Staff positions cited in the Dear CFO Letters are listed below and are compiled in an accounting matters bibliography that is available on the SEC’s website.
In other new Dear CFO Letters, the Staff: (i) modified its position with respect to the senior securities table audit requirement (2001-02) for BDCs and closed-end funds (CEFs) arising from changes to the offering disclosure requirements for such funds through the BDC-CEF offering reforms; (ii) modified its position on the methods by which registrants should be reporting a change in auditor (1998-04); and (iii) rescinded its position on average commission rate disclosure (1998-01), which is no longer required as a result of the BDC-CEF offering reforms.
The latest Dear CFO Letters and the accounting matters bibliography are available at the links below:
https://www.sec.gov/files/dear-cfo-letter-from-im-chief-accountant-102320.pdf
https://www.sec.gov/investment/accounting-matters-bibliography
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The opinions expressed are those of the author(s) and do not necessarily reflect the views of the firm or its clients, or any of its or their respective affiliates. This article is for general information purposes and is not intended to be and should not be taken as legal advice.
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