Exhibit 99.ACCT
EXHIBIT(a)(4)
KPMG LLP (KPMG) served as the independent registered public accounting firm of Prudential’s Gibraltar Fund, Inc. for the fiscal years ended December 31, 2018 and December 31, 2019. KPMG’s reports on the financial statements for the fiscal years ended December 31, 2018 and December 31, 2019 contained no adverse opinion or disclaimer of opinion nor were they qualified or modified as to uncertainty, audit scope or accounting principle. During such fiscal year-ends and through January 25, 2020, the date of dismissal, (i) there were no disagreements with KPMG on any matter of accounting principles or practices, financial statement disclosure or auditing scope or procedure, which disagreements, if not resolved to the satisfaction of KPMG, would have caused them to make reference to the subject matter of the disagreements in connection with their reports on Prudential’s Gibraltar Fund, Inc. financial statements for such period, and (ii) there were no “reportable events” of the kind described in Item 304(a)(1)(v) of RegulationS-K under the Securities Exchange Act of 1934, as amended.
On January 25, 2020, the Audit Committee and Prudential’s Gibraltar Fund, Inc.’s Board of Directors approved the engagement of PricewaterhouseCoopers LLP (PwC), to serve as the independent registered public accounting firm for Prudential’s Gibraltar Fund, Inc.’s fiscal year ending December 31, 2020, thereby replacing KPMG effective upon completion of their December 31, 2019 audit and issuance of their report thereon. During Prudential’s Gibraltar Fund, Inc.’s fiscal years ended December 31, 2018 and December 31, 2019 and through January 25, 2020, neither Prudential Gibraltar Fund, Inc., nor anyone on its behalf, consulted with PwC on items which: (i) concerned the application of accounting principles to a specified transaction, either completed or proposed, or the type of audit opinion that might be rendered on Prudential’s Gibraltar Fund, Inc.’s financial statements; or (ii) concerned the subject of a disagreement (as defined in paragraph (a)(1)(iv) of Item 304 of RegulationS-K) or reportable events (as described in
paragraph (a)(1)(v) of said Item 304).
February 28, 2020
Securities and Exchange Commission
Washington, D.C. 20549
Ladies and Gentlemen:
We were previously principal accountants for Prudential’s Gibraltar Fund, Inc., and under the date of February 12, 2020, we reported on the financial statements of Prudential’s Gibraltar Fund, Inc. as of and for the years ended December 31, 2019 and 2018. On January 25, 2020, we were dismissed as independent registered public accountant effective upon completion of the audit and the issuance of our report thereon dated February 12, 2020.
We have read the statements made by Prudential’s Gibraltar Fund, Inc. included under Item 13(a)(4) of FormN-CSR dated February 28, 2020, and we agree with such statements except that we are not in a position to agree or disagree with the statements that (1) the Audit Committee and Prudential’s Gibraltar Fund, Inc.’s Board of Directors approved the engagement of PricewaterhouseCoopers LLP (PwC) to serve as the independent registered public accounting firm, and (2) neither Prudential’s Gibraltar Fund, Inc., nor anyone on its behalf, consulted with PwC on items which: (i) concerned the application of accounting principles to a specified transaction, or the type of audit opinion that might be rendered on Prudential’s Gibraltar Fund, Inc.’s financial statements; or (ii) concerned the subject of a disagreement or reportable events.
Very truly yours,
KPMG LLP
