Valuation – What Investment Advisers Should Know

January 2015


In the release of Rule 206(4)-7 of the Investment Advisers Act of 1940, which was issued in December 2003 mandating investment advisers to adopt compliance programs1 (“Compliance Program Rule”), the Securities and Exchange Commission (“SEC”) outlined that such firms must implement policies and procedures covering, among other things, the “processes to value client holdings and assess fees based on those valuations.” Even though it has been over 11 years since the Compliance Program Rule was adopted, valuation is an area that can sometimes be overlooked, and even abused by investment advisers.

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