Accounting and Disclosure Information

Fund Disclosure at a Glance

Accounting and Disclosure Information (ADI)

Disclosure Reference Material

ACCOUNTING AND DISCLOSURE INFORMATION (ADI)

This page is intended to be an aid to practitioners and others who are interested in the law and interpretations concerning disclosure. The intent is to gather into one webpage various resources in areas that may be of interest. Below are several topics about which the Disclosure Review and Accounting Office (DRAO) receives frequent inquiries. Readers can click on a relevant link and see the resources that the staff has collected pertaining to that topic. We hope that these materials are helpful. Click here to receive updates.

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Category Title Last Updated
Accounting a - IMGU 2014-11 - Investment Company Consolidation

Accounting Investment Company Reporting Modernization Frequently Asked Questions

Accounting n - From the Chief Accountant, Letter to CFOs

From the Chief Accountant, Letter to CFOs

Applying SFAS #119 to Investment Companies, Presentation and Accounting for Enhanced Securities Valuation, Presentation, Transferrable Enhancements, and Contribution to Capital.
Accounting From the Chief Accountant, Letter to CFOs

Summary of Withdrawn, Modified, and Supplemented Items related to recent rulemakings and other staff observations
Accounting Valuation of Portfolio Securities and other Assets Held by Registered Investment Companies - Select Bibliography of the Division of Investment Management

Accounting IMGU 2013-07 - Business Development Companies - Separate Financial Statements or Summarized Financial Information of Certain Subsidiaries

Accounting Business Development Companies - Auditor Verification of Securities Owned

Accounting IM-INFO-2017-07 – Applicability of Staff Accounting Bulletin No. 118 to Investment Companies Impacted by the Tax Cuts and JOBS ACT

Accounting Frequently Asked Questions About Mutual Fund After-Tax Return Requirements

Accounting From the Chief Accountant, Letter to CFOs

From the Chief Accountant, Letter to CFOs

Senior Securities Table Disclosure, Pro Forma Financial Statements and Filings Pursuant to Rule 488 of the Securities Act of 1933, Financial Highlights and Financial Statements During Reorganizations When Performance is being Carried Over, and other topics.
Accounting From the Chief Accountant, Letter to CFOs

From the Chief Accountant, Letter to CFOs

Financial Highlights and Fee Table Disclosures, and other topics.
Accounting Accounting Matters Bibliography

Accounting From the Chief Accountant, Letter to CFOs

From the Chief Accountant, Letter to CFOs

Organization Costs for Open-end Investment Companies, Financial Reporting for a Master/Feeder Structure, Change in Accountants, and other topics.
Accounting From the Chief Accountant, Letter to CFOs

Reintroduction of Dear CFO Letters, Summary of Rescinded, Modified, and Supplemented Items, Business Development Companies – Auditor Verification of Securities Owned, Investment Company Act Section 19(a) Notice Requirements, and other topics.
Accounting From the Chief Accountant, Letter to CFOs

From the Chief Accountant, Letter to CFOs

Funds of Funds Considerations, Accounting for Securities Lending Transactions, and other topics.
Accounting From the Chief Accountant, Letter to CFOs

From the Chief Accountant, Letter to CFOs

Financial Highlights in Multi-Class Reorganizations, Accounting Treatment for Indirect Expenses, Dating of Financial Statements, and other topics.
Accounting From the Chief Accountant, Letter to CFOs

Summary of Rescinded, Modified, and Supplemented Items related to Change in Independent Public Accountant and Securities Offering Reform, and Observations on Initial Registration Statement Filings and Combined Financial Statements
Accounting From the Chief Accountant, Letter to CFOs

From the Chief Accountant, Letter to CFOs

Transactions with Affiliates in a Master/Feeder Structure, Financial Statement Presentation of Fee Waivers, Correction of Errors, and other topics.
Accounting From the Chief Accountant, Letter to CFOs

From the Chief Accountant, Letter to CFOs

Accounting For Certain Transactions with Affiliates, Valuation of Certain Portfolio Investments, Securities With Zero Value, and other topics.
Accounting From the Chief Accountant, Letter to CFOs

Summary of Withdrawn, Modified, and Supplemented Items related to recent rulemakings and other staff observations
Distribution Arrangements Frequently Asked Questions on IM Guidance Update 2016-06 (Mutual Fund Fee Structures)

Distribution Arrangements a - IMGU 2016-06 - Mutual Fund Fee Structures

Dividends and Distributions IMGU 2013-11 - Shareholder Notices of the Sources of Fund Distributions - Electronic Delivery

Electronic Communications IMGU 2013-01 - Filing Requirements for Certain Electronic Communications

Fees and Expenses Disclosure of Fund of Funds Expenses (May 23, 2007)

Filing Procedures Derivatives Rule: Updated Reporting Forms Available for Fund Filers

Derivatives Rule: Updated Reporting Forms Available for Fund Filers [date: 2/16/2022]
Filing Procedures b - EDGAR

EDGAR
Filing Procedures ADI 2024-13: Short-Form Registration Statements on Form N-2 and Timeliness of Required Reports Filed by WKSIs and Other Seasoned Issuers

Filing Procedures ADI 2018-01 - Expanded Use of Draft Registration Statement Review Procedures for Business Development Companies

Filing Procedures ADI 2024-14: Tailored Shareholder Report Common Issues

Filing Procedures ADI 2018-02 - Template Filing Relief

Filing Procedures ADI 2019-07 – Review of Certain Filings Under Automatic Effectiveness Rules

Filing Procedures ADI 2018-03 - Filing information statements in connection with multi-manager exemptive relief

Filing Procedures ADI 2018-04 - Marked copies of amendments to registration statements

Filing Procedures ADI 2018-06 - Requests for Selective Review

Filing Procedures EDGAR

EDGAR
Fund Names IMGU 2013-12 - Fund Names Suggesting Protection From Loss

Fund Names Frequently Asked Questions about Rule 35d-1 (Investment Company Names)

Performance ADI 2022-12 – SEC Yield for Funds That Invest Significantly in TIPS

Performance ADI 2019-09 - Performance and Fee Issues

Principal Risks a - IMGU 2016-02

Principal Risks Staff statement regarding the risk legend used by non-transparent exchange-traded funds operating in reliance of an exemptive order under the Investment Company Act of 1940

Principal Risks ADI 2019-08 - Improving Principal Risks Disclosure

Principal Risks ADI 2020-11 Registered Funds’ Risk Disclosure Regarding Investments in Emerging Markets

Principal Strategies IMGU 2014-08 - Guidance Regarding Mutual Fund Enhanced Disclosure

Principal Strategies Staff Letter: Engaging on Fund Innovation and Cryptocurrency-related Holdings

Principal Strategies Derivatives-Related Disclosures by Investment Companies

Principal Strategies Staff Statement on Funds Registered Under the Investment Company Act Investing in the Bitcoin Futures Market

Proxy Materials IMGU 2014-02 - Unbundling of Proxy Proposals-Investment Company Charter Amendments

Specialty Funds IMGU 2013-05 - Disclosure and Compliance Matters for Investment Company Registrants That Invest in Commodity Interests

Variable Insurance Products ADI 2018-05 - Use of rate sheet supplements in connection with variable insurance products

Variable Insurance Products Auditing Standards for Financial Statements of Insurance Company Depositors of Variable Insurance Products, Staff Letters (March 8, 2005)

Variable Insurance Products ADI 2020-10 - Filing and Delivery Obligations for Certain Discontinued Variable Insurance Contracts

Last Reviewed or Updated: Oct. 23, 2020