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Comment Letter - SEC’s proposal on funds’ good faith determinations of fair value


In our comment letter, we support the SEC’s proposal to rescind Accounting Series Release (ASR) No. 113 and ASR No. 118.The SEC proposed rescinding the ASRs as part of a broader proposal to modernize fund valuation practices and clarify how fund boards can satisfy their obligation to determine fair value in good faith for portfolio holdings without readily available market quotations. The ASRs, which were issued in 1969 and 1970, provide guidance on the role of fund boards in fair value determinations and on certain accounting and auditing matters related to fund investments.

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