Update: Independence and the "Loan Rule"

Posted by John Braun on Oct 2, 2017 11:00:00 AM

As detailed in a previous post, Regulation S-X Rule 2-01(c)(1)(ii)(A) (the "Loan Rule") prohibits accounting firms from having certain financial relationships with their audit clients and affiliated entities. 

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What's New With Regulation S-X? A Look At The SEC's Recent Amendments

Posted by John Braun on Jan 19, 2017 2:00:39 PM

In October 2016, the SEC adopted amendments to Regulation S-X as part of its Investment Company Reporting Modernization efforts. These amendments:

  • Update specific disclosure requirements for most types of derivatives
  • Update disclosures for other investments as well as investments in and advances to affiliates
  • Amend certain rules regarding the general form and content of financial statements

Most of the disclosure requirements are already in place in the industry.  The effective date of these amendments is August 1, 2017. However, certain modifications have been made that are important to communicate. Below, you’ll find a summary of the significant points in the recent amendments along with brief notes on changes from current practice.

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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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Independence and the "Loan Rule"

Posted by John Braun on Jun 20, 2016 2:00:00 PM

There has been much press recently about potential independence issues for certain Big Four auditors of mutual funds as a result of the SEC’s “Loan Rule.”  However, it is not uncommon for large audit firms to have independence issues outside of the “Loan Rule” given their volume of employees, relationships with banks, advisors, etc., as well as audit clients.

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Money Market Fund Reform - Status Update

Posted by John Braun on Jun 6, 2016 2:00:00 PM

Almost two years ago, the SEC adopted amendments to the rules that govern money market mutual funds meant to address the risk of investor runs in money market funds. In summary, the rules in part:

  1. Require a floating NAV for institutional prime money market funds
  2. Allow for fees and gates to discourage and/or suspend redemptions temporarily at certain asset thresholds
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An Audit Partner Asks… What Are the True Drivers of Audit Quality? Reaction to the PCAOB’s Adoption of New Rules Requiring Engagement Partner Disclosure

Posted by John Braun on Apr 15, 2016 1:30:00 PM

Subject to the approval of the SEC, new PCAOB rules will require individual audit partner disclosure on audit reports issued after June 30, 2017, along with other information regarding other accounting firms participating in the audit. The disclosure will take place in a filing separate from that which includes the Report of the Registered Public Accounting Firm - Form AP.

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From Stradley Ronon- To RIC or Not to RIC… An Analysis of Tax Issues When Converting to a Regulated Investment Company

Posted by admin on Apr 11, 2016 4:00:00 PM

From time to time, we receive resources from industry colleagues that we believe would be of value to our clients and industry friends.

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Determining When a Statement of Cash Flows is Required for an Investment Company

Posted by admin on Aug 18, 2014 4:47:00 PM

Generally speaking, investment companies are exempt from presenting a statement of cash flows in their semi-annual and annual reports, provided they meet three conditions.

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Can Funds Use Equalization Debits and In-Kind Redemptions Together For Tax Efficiency?

Posted by admin on Aug 5, 2014 4:26:00 PM

In order to achieve tax efficiency and maintain the single layer of taxation concept of Subchapter M, regulated investment companies (RICs) use various techniques. Two common techniques in the industry are equalization debits and the use of redemptions in-kind instead of cash redemptions. ETFs tend to use in-kind redemptions more than non-ETF groups.

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Shortening the U.S. Trade Settlement Cycle

Posted by admin on Jun 17, 2014 3:27:00 PM

In a recent report published by the Depository Trust & Clearing Corporation (DTCC) in April of 2014, a recommendation was made to shorten the U.S. Trade settlement cycle for equities, municipal and corporate bonds and unit investment trusts from trade date plus three days (T+3) to trade date plus two days (T+2).

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