Certificate of Chief Compliance Officer
In regard to the Interfund Lending program, I certify that each Portfolio and the Adviser have established procedures reasonably designed to achieve compliance with the terms and conditions of the exemptive order dated April 2, 2014, pursuant to certain sections of the Investment Company Act of 1940. These procedures, which have been previously approved by the Board of Directors/Trustees of the Portfolios, include the following objectives:
(a) that the Interfund Loan Rate will be higher than the Repo Rate, and, if applicable, the one-day yield on any money market fund in which the lending Portfolio could otherwise invest, but lower than the Bank Loan Rate;
(b) compliance with the collateral requirements as set forth in the application for exemptive relief filed on September 5, 2013, and amended on February 18, 2014;
(c) compliance with the percentage limitations on interfund borrowing and lending;
(d) allocation of interfund borrowing and lending demand in an equitable manner and in accordance with procedures established by the Board; and
(e) that the Interfund Loan Rate does not exceed the interest rate on any third-party borrowings of a borrowing Portfolio at the time of the Interfund Loan.
/s/ Randy Olson
Randy Olson (Jan 3, 2023 11:35 EST)
Chief Compliance Officer
Date: 01/03/23
To the Board of Directors of Dimensional Investment Group Inc. and Shareholders of the Portfolios listed in Appendix A, (hereafter collectively referred to as the “Portfolios”)
In planning and performing our audits of the financial statements of the Portfolios as of and for the year ended October 31, 2022, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), we considered the Portfolios’ internal control over financial reporting, including controls over safeguarding securities, as a basis for designing our auditing procedures for the purpose of expressing our opinion on the financial statements and to comply with the requirements of Form N-CEN, but not for the purpose of expressing an opinion on the effectiveness of the Portfolios’ internal control over financial reporting. Accordingly, we do not express an opinion on the effectiveness of the Portfolios’ internal control over financial reporting.
The management of the Portfolios is responsible for establishing and maintaining effective internal control over financial reporting. In fulfilling this responsibility, estimates and judgments by management are required to assess the expected benefits and related costs of controls. A company’s internal control over financial reporting is a process designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements for external purposes in accordance with generally accepted accounting principles. A company’s internal control over financial reporting includes those policies and procedures that (1) pertain to the maintenance of records that, in reasonable detail, accurately and fairly reflect the transactions and dispositions of the assets of the company; (2) provide reasonable assurance that transactions are recorded as necessary to permit preparation of financial statements in accordance with generally accepted accounting principles, and that receipts and expenditures of the company are being made only in accordance with authorizations of management and directors of the company; and (3) provide reasonable assurance regarding prevention or timely detection of unauthorized acquisition, use or disposition of a company’s assets that could have a material effect on the financial statements.
Because of its inherent limitations, internal control over financial reporting may not prevent or detect misstatements. Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.
A deficiency in internal control over financial reporting exists when the design or operation of a control does not allow management or employees, in the normal course of performing their assigned functions, to prevent or detect misstatements on a timely basis. A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the company’s annual or interim financial statements will not be prevented or detected on a timely basis.
Our consideration of the Portfolios’ internal control over financial reporting was for the limited purpose described in the first paragraph and would not necessarily disclose all deficiencies in internal control over financial reporting that might be material weaknesses under standards established by the PCAOB. However, we noted no deficiencies in the Portfolios’ internal control over financial reporting and its operation, including controls over safeguarding securities, that we consider to be a material weakness as defined above as of October 31, 2022.
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PricewaterhouseCoopers LLP, Two Commerce Square, Suite 1800, 2001 Market Street, Philadelphia, PA 19103-7042 T: (267) 330-3000, F: (267) 330-3300, www.pwc.com/us |
This report is intended solely for the information and use of the Board of Directors of Dimensional Investment Group Inc. and the Securities and Exchange Commission and is not intended to be and should not be used by anyone other than these specified parties.
/s/PricewaterhouseCoopers LLP
Philadelphia, Pennsylvania
December 22, 2022
Appendix A
DFA International Value Portfolio
U.S. Large Company Portfolio
DFA Two-Year Fixed Income Portfolio
DFA Two-Year Government Portfolio
Global Equity Portfolio
Global Allocation 60/40 Portfolio
Global Allocation 25/75 Portfolio
DFA International Value Portfolio III
U.S. Large Cap Value Portfolio III
Emerging Markets Portfolio II