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United States securities and exchange commission logo
January 28, 2022
Thomas Wojcik
Chief Financial Officer
Affiliated Managers Group, Inc.
777 South Flagler Drive
West Palm Beach, Florida 33401
Re: Affiliated Managers
Group, Inc.
Form 10-K filed
February 19, 2021
Form 10-Q filed
November 5, 2021
Response dated
January 21, 2022
File No. 001-13459
Dear Mr. Wojcik:
We have reviewed your January 21, 2022 response to our comment
letter and have the
following comments. In some of our comments, we may ask you to provide
us with information
so we may better understand your disclosure.
Please respond to these comments within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe our
comments apply to your facts and circumstances, please tell us why in
your response.
After reviewing your response to these comments, we may have
additional
comments. Unless we note otherwise, our references to prior comments are
to comments in our
December 22, 2021 letter.
September 30, 2021 Form 10-Q
Note 4. Other Investments, page 9
1. Please refer to comment
11. For interests in private equity funds accounted for using the
equity method of
accounting, please tell us the guidance in ASC 323 that supports
measuring the interest
at fair value and using the NAV as a practical expedient. Please tell
us how your disclosure
and accounting policies are consistent with the guidance in ASC
323-10-35.
2. Please refer to comment
11. Please clarify for us how you considered whether
investments accounted
for under ASC 321-10-35-2 were in the scope of ASC 323. If they
were, please tell us
how you determined your accounting policies were consistent with the
Thomas Wojcik
Affiliated Managers Group, Inc.
January 28, 2022
Page 2
guidance in ASC 323.
3. Please refer to comment 12. Please tell us why you believe your
disclosure that you
consolidate affiliate sponsored investment products if your interests
are considered
substantial is consistent with the accounting determinations discussed
in your response
and as disclosed on page 11. Alternatively, revise your disclosure in
future filings to
clarify your consolidation policies for affiliate sponsored investment
products.
You may contact Mike Volley, Staff Accountant, at 202-551-3437 or Amit
Pande,
Accounting Branch Chief, at 202-551-3423 if you have questions.
FirstName LastNameThomas Wojcik Sincerely,
Comapany NameAffiliated Managers Group, Inc.
Division of
Corporation Finance
January 28, 2022 Page 2 Office of Finance
FirstName LastName