James Kaiser

Recent Posts

Securities Lending Fees – Income or Expense Offset?

Posted by James Kaiser on Oct 24, 2019 5:28:58 PM

I’ve recently had some mutual fund and ETF clients ask if they can reflect securities lending fees as an offset to expenses, as opposed to income on their fund’s Statement of Operations. While this alternative presentation would not have any impact on the reported net investment income of the fund, it would serve to reflect a reduced net expense ratio, which could be helpful in marketing the fund to investors.  My initial reaction to this question was- “No, of course not!”  However, after performing a little research, the answer is actually “maybe.”

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Launching an Interval Fund? 5 Important Audit and Tax Considerations

Posted by James Kaiser on May 28, 2019 4:39:08 PM

In recent years, we have seen an increase in the popularity of interval funds.  Interval funds are hybrid products that contain characteristics of both open-end and closed-end funds.  Like open and closed-end funds, they are registered under the Investment Company Act of 1940 and generally take subscriptions daily, although some interval funds may take subscriptions less frequently than daily.

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Surprise! What You May Not Know About the SEC's Custody Rule:  Jim Kaiser Authors Article For the Investment Adviser Association Newsletter

Posted by James Kaiser on Aug 13, 2018 6:27:00 PM

Investment advisers deemed to have custody of client funds or securities:  Is your accounting firm both registered with, and subject to regular inspection by, the Public Company Accounting Oversight Board?  In certain situations, it's an important question.  Jim Kaiser explores this and other questions about the SEC's Custody Rule in a recent issue of the Investment Adviser Association newsletter.

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Another ETF Accounting Trap

Posted by James Kaiser on May 7, 2018 3:30:12 PM

Today I am writing about an accounting error I have been seeing more and more while performing audits of exchange traded funds (“ETFs”).

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Considerations For Mutual Funds For Allocating Earnings and Profits to Distributions

Posted by James Kaiser on Oct 10, 2016 7:05:00 PM

In this post, we’ll consider the following:

  • Current requirements, as updated by the RIC Modernization Act of 2010, for allocating earnings and profits across multiple distribution dates in instances where total annual distributions exceed earnings and profits for funds that have fiscal year ends that span two calendar years (e.g.  non-calendar fiscal year end funds)
  • Why this requirement may impact the reporting of distributions in a semi-annual report
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