SEC Commissioner addresses Valuation Issues – Compliance Alert

Last month, Commissioner Luis A. Aguilar of the U.S. Securities and Exchange Commission gave a speech ( to the Regulatory Compliance Association in New York. The speech was focused on compliance as the foundation on which investor trust is built and kept. An effective and robust compliance program that is embedded into an entity’s investment culture from top to bottom is the cornerstone of an investment adviser’s responsibility to its clients.

One focus of the speech was on the SEC’s continued findings relating to the misconduct of portfolio valuation. As stated by the Commissioner, “We all know the importance of valuation and that there are inherent conflicts of interests that may arise in the valuation of investments.” Later on, he stated: “Valuation of assets is an area that the Commission will continue to look into; I encourage those of you with compliance responsibilities to pay close attention to your firm’s valuation processes. An ounce of prevention will be worth a pound of cure.”

Houlihan Capital can prepare and review a fund’s valuation policies and provide clients with independent valuations of assets ranging from single investments to multi-class portfolios. The firm has a history of working closely with regulators, auditors, third-party administrators, investors, and some of the world’s largest private investment funds.

For more information regarding Fair Value Best Practices and Implementation, please see Houlihan Capital’s white paper on Fair Value Best Practices and Implementation. For more information on independent third party valuation services, please visit, contact Paul Clark ( at 312-450-8656.

Houlihan Capital is a leading, solutions-driven valuation, financial advisory and boutique investment banking firm committed to delivering superior client value and thought leadership in an ever-changing landscape. The firm has extensive experience in providing objective, independent and defensible opinions of value that meet accounting and regulatory requirements. Our clients include some of the largest asset managers around the world, and private equity funds, hedge fund advisors, fund administrators, and other asset management firms benefit from Houlihan Capital’s comprehensive valuation and financial advisory services. Houlihan Capital is a Financial Industry Regulatory Authority (FINRA) and SIPC member, committed to the highest levels of professional ethics and standards.

Related Posts