United States: Mark My Words: SEC Staff Guidance on Private Credit Valuation
By Thoreau A. Bartmann, Sasha Burstein, Lance C. Dial, Pablo J. Man, and George Zornada
On 28 September 2026, the Chief Accountant and the Director of the Division of Investment Management issued a joint statement on fair valuation of private assets (the “Statement”). On its face, it doesn’t break much ground, as it mostly restates existing guidance. However, the most important thing about this statement may be that it was issued at all. With this statement, the underlying message is clear: the SEC staff is looking for robust valuation policies and procedures coupled with material disclosures.
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