MFA Comments to Financial Accounting Standards Board on Fair Valuing Investments in Investment Companies

MFA submitted a letter to the Financial Accounting Standards Board today in response to the proposed FASB staff guidance (the “FSP”) on fair valuing investments in investment companies that have calculated net asset value per share in accordance with the AICPA Audit and Accounting Guide, Investment Companies. In our letter, MFA recommended that: (i) FASB adopt the practical expedient set out in the FSP as a permissive standard that would permit a reporting entity to estimate the value of its investment in an investment company within the scope of the FSP as the net asset value of that investment company; (ii) FASB consider modifying the disclosures required of reporting entities using the practical expedient to permit disclosure of aggregated investment positions, or, in the alternative, establish a materiality threshold for disclosures of individual investment positions; and (iii) FASB consider including a standard that a reporting entity should have a reasonable belief that the underlying investment company calculates its net asset value per share in accordance with the AICPA guide for the reporting entity to be able to use the practical expedient.