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Download (IASB) Exposure Draft (ED 10), “Consolidated Financial Statements”
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September 18th, 2009 International Accounting Standards Board First Floor 30 Cannon Street London, United Kingdom EC4M 6XH Attention: Ruane Barbara, Michael Buschhueter and Patrina Buchanan Dear Sir/Madams The Institutional Limited Partners Association is a not-for-profit association committed to serving limited partner investors in the global private equity industry by facilitating valueadded communication, enhancing education in the asset class and promoting research and standards in the private equity industry. ILPA has over 215 institutional member organizations that collectively manage approximately $1 trillion of private equity assets. Our reach is both geographically and organizationally diverse - ranging from large pension funds to endowments, to single family offices – with global representation. The ILPA is therefore particularly well positioned to comment on the “user value” of the consolidation of private equity investments. The ILPA is pleased to respond to the International Accounting Standards Board (IASB) Exposure Draft (ED 10), “Consolidated Financial Statements.” Specifically, ED 10 asks “whether the enhanced disclosure requirements for consolidated and unconsolidated entities will give capital providers and other users of financial statements information that is useful for their decision-making.” In North America, virtually all private equity funds are required to report to their LPs using GAAP accounting as specified in their partnership agreements. Such accounting requires that private equity investments – often a majority of the outstanding voting shares of private companies – be carried at fair value. This is the method of accounting that best meets the needs of private equity investors, typically endowments, pension plans, foundations, insurance companies, and high net worth individuals. Because private equity funds hold securities of their portfolio companies for capital appreciation with a view toward returning realized gains to investors over a long horizon, it is not appropriate to view these investments on a consolidated basis with the activities of the fund or other portfolio companies. If private equity funds were required to consolidate portfolio companies as contemplated under ED 10, it would create significant difficulties for their investors and erode the relevance and comparability of the financial statements. In a previous filing to the Financial Accounting Standards Board in 2006, ILPA stated that LPs depend upon fair value reporting on private equity fund investments to communicate reliably and comparably with their respective stakeholders. Consolidation would impair LPs’ ability to compare the performance of private equity funds to other asset classes and could also compromise net returns as the cost of preparing unwanted consolidated financials is borne by the partners in the fund. We have not altered our position. The ILPA recently released the ILPA Private Equity Principles, a set of best practices that address issues relating to fund reporting and transparency; a report that is particularly relevant to this issue. We have attached that document for your review. You will note that the Principles also include best practices around fund governance and alignment of interest between GPs and LPs. Collectively the principles support and outline solid methods of ensuring open communication and reporting which directly speaks to what the IASB is trying to achieve. For reasons as noted above, IASB’s ED 10 should be amended to permit private equity funds to report the value of their investments at fair value. We thank the IASB for the opportunity to comment on the “user value” of consolidated financial statements for private equity investments. Regards, Kathy Jeramaz-Larson Executive Director Institutional Limited Partners Association