Stock-Based Compensation Pathway

A disciplined record of the inputs, assumptions, and estimates behind every RSU, stock option, and warrant — calibrated to the most recent round, and ready for the next.

01
Regulatory Paradigm

In the absence of a public trading market, a value for the company's common stock should consider all relevant facts and circumstances, including: recent arm's-length transactions, independent appraisals, the proximity of the issuance to the offering, intervening events, transfer restrictions and exercise dates, and profitability and financial condition of the company at the date of the valuation.

SEC Division of Corporation Finance — Financial Reporting Manual §7520.1 (updated 6/30/25)
Nick Says Solutions

Built for share-based compensation fair value.

  • Document KPIs, milestones, and forecast inputs between measurement dates.
  • Carry forward calibrated inputs from your most recent funding round.
  • Identify the principal market and track its dynamics throughout the year.
  • Document secondary transactions that inform fair value.
  • Structured capture of qualitative audit evidence for Level 3 inputs.
02
Principal Market
“The valuation should consider all the relevant facts and circumstances to assess what the price of the equity security would be in the principal marketat the measurement date.”
— AICPA Accounting & Valuation Guide · Equity Securities Issued as Compensation (20-Jun-24)

Nick Says organizes the evidence behind each measurement date — the KPIs, milestones, and calibrated inputs that carry forward from the most recent round to what the principal market would pay today.

03
Calibration & Evidence

Calibrated inputs, carried forward with discipline.

KPI & Projection Tracking

Document KPIs, milestones, and forecast inputs between measurement dates — the evidence auditors need to evaluate your Level 3 assumptions.

Funding Round Calibration

Carry forward calibrated inputs from your most recent round and adjust for current comparable data and changes in the company itself.

Principal Market

Identify the principal market, track its dynamics throughout the year, and document secondary transactions that inform fair value.

Audit Evidence for Level 3 Inputs

Structured capture of qualitative evidence — comments, source documents, and methodology notes — organized for efficient auditor review.

Calibration is used with various valuation techniques. To estimate fair value on subsequent measurement dates following initial measurement or funding round, the calibrated inputs are carried forward and adjusted to reflect current comparable data and any changes in the company itself.

AICPA Accounting & Valuation Guide — Valuation of Portfolio Company Investments of Venture Capital and Private Equity Funds, §10.05–.06 (1-Jun-19)

Start Your Valuation Process

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