Built for Investment Companies (funds) Estimating Fair Value

Under ASC 946, investment companies measure portfolio securities at fair value. For privately held holdings, Level 3 unobservable inputs — such as forecasts — are the primary driver of those estimates.

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01
Regulatory Paradigm
$31 trillion
in private market funds today.
Brian Daley — Securities and Exchange Commission, Private Markets Roundtable (March 4, 2026)
Valuations of private assets are infrequent and often subjective, which can create the illusion of stability. This underscores the importance of fiduciary oversight and professional management in evaluating, selecting, and monitoring such investments.
Commissioner Mark T. Uyeda — “The Diversification Deficit: Opening 401(k)s to Private Markets” (20-Nov-25)
Nick Says Solutions

Built for private investment company fair value.

  • Monitor up to 30 portfolio investments (debt or equity).
  • Support NAV calculations for distributions and/or share redemption (SEC Rule 2a-4).
  • Clean documentation for BOD discussions.
  • Document and track Level 3 assumptions over time.
  • Supplement Fund-of-Funds data with internal data and analysis.
  • Impose quarterly tracking of key inputs to forecasts.
02
Fair Value Determination
“The current net asset value of any investment owned by a registered investment company shall be valued at fair value as determined in good faith by the board of directors.”
— Investment Company Act of 1940 · § 17b fn-4(a)(1)

Nick Says supports the NAV workflow end to end — structured workpapers, methodology records, and the kind of documentation the BOD and your auditors expect to see quarter after quarter.

03
BOD Oversight & Documentation

A methodology record that stands up to fiduciary and auditor scrutiny.

BOD Discussion Documentation

Clean, organized documentation of methodology, assumptions, and challenges raised — ready for BOD review and the SEC's six-year retention requirement.

Level 3 Assumption Trail

Document and track Level 3 assumptions over time — who changed what, when, and why — so the methodology record stands up to fiduciary and auditor scrutiny.

NAV for Financial Statement Audits

Support audit-ready NAV calculations with structured workpapers — methodology, significant assumptions, and source documentation organized quarter over quarter.

Registered investment companies shall maintain appropriate documentation to support fair value determinations (six years). Maintain reports and other information provided to the BOD regarding fair value.
SEC Investor Advisory Committee — Rule 31a-4 (Sept. 18, 2025)
04
SEC Rule 2a-5

Fair Value Determination by Registered Investment Companies.

Portfolio Monitoring

Monitor up to 30 debt or equity portfolio investments with a consistent quarterly workflow — positioned around the reporting-date discipline that auditors and BODs expect.

Fund-of-Funds Supplement

Supplement third-party Fund-of-Funds data with your own internal analysis — closing the gap between underlying-fund reporting and your own valuation designee's judgment.

Quarterly Input Tracking

Impose quarterly tracking of the key inputs to forecasts — forcing the discipline that Rule 2a-5 contemplates and that auditors increasingly look for.

Start Portfolio Monitoring

Bring structure, continuity, and a methodology record to your quarterly fair value practice.

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