SEC Division of Investment Management ("Division") Chief Accountant Alison Staloch highlighted guidance on "certain accounting, auditing, financial reporting, or other related disclosure matters."

In a "Dear CFO Letter," the Division highlighted recent guidance that "Staff believes may require additional clarification in light of market and regulatory developments, consultations with or inquiries from market participants, or other previously expressed Staff views." The updates pertain to:

  • average commission rate disclosures;
  • change in independent public accountants;
  • senior securities table disclosures;
  • determining commencement of operations date;
  • initial registration statements; and
  • combined financial statements.

Primary Sources

  1. SEC Comment Letter: Dear CFO Letter from Chief Accountant

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