Investment Companies - Contractual Sale Restrictions (BDO Comment Letter)

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On July 1, 2026, the FASB issued an Exposure Draft proposing amendments for investment companies with equity securities subject to contractual sale restrictions. The proposed amendments would provide investment companies within the scope of ASC 946, Financial Services — Investment Companies, an exception to ASC 820, Fair Value Measurement, by requiring them to consider a contractual sale restriction in measuring the fair value of the equity security.

In our comment letter, BDO generally supported the Board’s proposal, noting it represents a reasonable and pragmatic response to concerns raised by investment company stakeholders regarding the effect of contractual sale restrictions on net asset value (NAV) management fees, and performance reporting outcomes.