Regulatory ·
SEC staff statement on fair value of private assets puts private credit marks, PIK and non-accrual disclosure in focus
A reminder, not new rules: calibrate models to transactions and current market evidence, avoid boilerplate Level 3 disclosure, and consider disclosing non-accrual, non-performing and PIK where material. WilmerHale notes it may inform Exams and Enforcement.
Why it matters for deal teams: Valuation committees need an evidence pack per mark: comps, other holders' marks, and why yours differs. That's assembly work an agent does well.
Source: SEC (Hohl, Daly) ↗ · more ↗
Related workflows
- PCT-034 · The SEC asked how you calibrate your marks. An agent builds the evidence pack for every Level 3 loan
- PCT-003 · Same loan, different marks: who else holds your borrower, how they value it, and who might sell
- PCT-011 · Cash to PIK, caught in the filing: flag every loan that switched to paying in kind this quarter