United States securities and exchange commission logo
December 11, 2020
Daniel Levin
Chief Financial Officer
Oaktree Capital Group, LLC
333 South Grand Avenue, 28th Floor
Los Angeles, CA 90071
Re: Oaktree Capital
Group, LLC
Form 10-K for the
Fiscal Year Ended December 31, 2019
Filed March 2, 2020
Form 10-Q for the
Quarterly Period Ended September 30, 2020
Filed November 6,
2020
File No. 001-35500
Dear Mr. Levin:
We have limited our review of your filing to the financial
statements and related
disclosures 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.
Form 10-K for the Fiscal Year Ended December 31, 2019
Business
Asset Classes and Investment Strategies, page 9
1. We note your
disclosures regarding asset classes and investment strategies. In your future
filings, please revise
here or within MD&A to include tabular and / or narrative discussion
of fund investment
performance, such as rates of return, comparison against benchmarks,
or other applicable
metrics by asset class, by strategy, and for any key funds.
Management s Discussion and Analysis of Financial Condition and
Results of Operations
Operating Metrics, page 49
2. We note your disclosure
of incentive-creating assets under management ("AUM") at the
Daniel Levin
Oaktree Capital Group, LLC
December 11, 2020
Page 2
end of each reporting period with related definition disclosed on page
44. In your future
filings, please revise to provide a rollforward, preferably in tabular
format, of both your
incentive-creating and total AUM showing the beginning balance, gross
inflows, gross
outflows, market appreciation/depreciation, and foreign exchange
impacts, to arrive at
ending AUM balances for all periods presented. In addition, supplement
your revised
disclosure with a discussion of weighted average fee rates (by asset
class, type, etc.) along
with narratives explaining significant trends, and enhance your
discussion of how specific
asset mix shifts are impacting revenues.
Form 10-Q for the Quarterly Period Ended September 30, 2020
Management s Discussion and Analysis of Financial Condition and Results of
Operations
Nine Months Ended September 30, 2020 Compared to the Nine Months Ended
September 30,
2019
Net Change in Unrealized Appreciation (Depreciation) on Consolidated Funds
Investments,
page 73
3. We note the significant depreciation on the consolidated funds'
investments during the
nine months ended September 30, 2020 compared to the gain during the
nine months
ended September 30, 2019. In your future filings, please revise to
provide a more fulsome
discussion of significant factors, investment concentrations and
activities driving the
change in the results of operations. For example, disclose more
qualitative and
quantitative details about the funds impacted, industry or geographic
concentrations, or
other significant factors impacting the valuation of the investments.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
You may contact Robert Klein, Staff Accountant, at 202-551-3847 or Cara
Lubit, Staff
Accountant, at 202-551-5909 with any questions.
FirstName LastNameDaniel Levin Sincerely,
Comapany NameOaktree Capital Group, LLC
Division of
Corporation Finance
December 11, 2020 Page 2 Office of
Finance
FirstName LastName