Published on Sep 8th, 2022 |

Brief Introduction

Chuck Martin and Ryan Hurley were both quoted in Ignites providing their thoughts and insights towards the SEC’s Fair Value Rule that is now effective as of today, September 8th, 2022.

Insights From Chuck Martin

Regarding the day-to-day role in fair value determination, Chuck stated that the Board is not involved in that role.

As it relates to small shops, Chuck believes that it is much easier said than done keeping the Portfolio Manager separate from the valuation designee, and that the CCO could become the valuation designee by default, despite knowing nothing about the valuation process.

Before the Rule became effective, valuation processes were more ad hoc for some shops, Chuck said. He concluded his thoughts and insights by stating that small shops are going through more challenges implementing the fair value rule, like many SEC rules.

Insights From Ryan Hurley

Ryan was quoted on the valuation designee topic, where he stated that “many shops have also assigned roles within their valuation designee committees.”

It has been seen that the Chair of the committee has been chosen as the program administrator in some instances.

If you have any questions relating to 2a-5 or need assistance, do not hesitate to reach out to Vigilant as we are happy to help.

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