Practice question, Valuation

Walk through the valuation of one fair-valued or illiquid position from pricing source to final value, including any pricing override and who approved it.

Taft practice question: not an official regulator question. SEC Division of Examinations, United States (federal). For SEC-registered investment advisers. Evidence category: Valuation records.

Not legal advice. A practice prompt for rehearsing how your team explains its controls and evidence. No scoring, no model answer, no implication that a regulator will ask these words.

Authored by Taft. Last checked 2026-11-09. All questions.

Why it is relevant

  • The typical initial request list includes the valuation process, fair-valued and illiquid securities held by clients, and pricing overrides, and the 2027 priorities name valuation among the compliance program components reviewed.

    Sources: [1] Attachment, Valuation, [2] Section I.B, Compliance Programs

Evidence to locate

Suggested, not mandatory. A regulator's actual request list governs.

No evidence cues listed.

Follow-up prompts

  • How does the valuation feed the fee calculation for that account?

Applicability

Applies to
Advisers registered or required to be registered with the SEC.
Does not apply to
Not stated.

Cite

Cite the official source first. Then: Taft Compliance Group, Exam-prep toolkit (draft), question q-valuation-process, https://taftcompliance.com/resources/exam-prep-toolkit/questions/q-valuation-process, last checked 2026-11-09.

Sources

  1. U.S. Securities and Exchange Commission, Division of Examinations, Risk Alert: Investment Advisers: Assessing Risks, Scoping Examinations, and Requesting Documents (staff statement). regulator guidance. Attachment, Typical Initial Information Examiners Request of Investment Advisers: Compliance Program and Oversight Process; Valuation; Information Processing, Reporting, and Protection.

    https://www.sec.gov/files/risk-alert-ia-risk-and-requesting-documents-090623.pdf

    Checked 2026-11-09; published 2023-09-06.

    Supporting passage

    Compliance policies and procedures in effect during the examination period. Tests performed (i.e., compliance reviews, quality control analyses, surveillance, and/or forensic or transactional tests performed by the firm). Annual and/or interim reviews of policies and procedures, including any reports prepared. Record of compliance exceptions. Inventory of compliance risks and conflicts of interest that forms the basis for policies and procedures and notations regarding changes made to the inventory. Valuation process. Fair-valued and illiquid securities held by clients. Advisory fee calculations. Pricing overrides. Safeguards for the protection of customer records and information. Business continuity plan. Cybersecurity incidents or breaches (e.g., incident description, impact, and remediation).

  2. U.S. Securities and Exchange Commission, Division of Examinations, Fiscal Year 2027 Examination Priorities (staff statement). regulator guidance. Section I.B, Compliance Programs, page 6.

    https://www.sec.gov/files/2027-exam-priorities.pdf

    Checked 2026-11-09.

    Supporting passage

    The Division's evaluation of compliance program effectiveness is a critical element of the examination process. The Division will review key components of an adviser's compliance program that address areas of its business and operations such as marketing, valuation, trading, portfolio management, disclosure and filings, and custody, as appropriate for each specific examination. Examinations will also typically analyze an adviser's annual compliance review. The Division continues to prioritize review of whether policies and procedures are reasonably designed to address conflicts of interest, in light of a firm's particular operations, and to prevent advisers from placing their interests ahead of clients' interests. Examinations will focus on whether the policies and procedures are implemented, and whether disclosures address fee-related conflicts of interest, particularly those arising from account and product compensation structures.

Changes to this question

No released changes.

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