Disclosure of portfolio holdings (Series 1.0)
Portfolio disclosure is one area where regulators and accounting rule makers will continue their efforts to promote more transparency. This paper summarises the requirements under accounting principles generally accepted in the United States (GAAP) and of the US Commodity Futures Trading Commission (CFTC) for private investments funds to provide disclosure of portfolio holdings.
The key portfolio disclosure requirements under Statement of Position 95-2 (Financial Reporting by Nonpublic Investment Partnerships), SOP 01-1 (Amendment to Scope of Statements of Position 95-2, Financial Reporting by Nonpublic Investment Partnerships, to include commodity pools), AICPA Audit and Accounting Guide and the Division of Trading and Markets of the CFTC annual letters to commodity pool operators have been summarized to provide this guidance.
This paper summarises some of the frequently asked questions and other informational points regarding these requirements. Suggested actions are provided for fund managers to meet these requirements.
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