Perspectives on valuation.

October 15, 2026

The SEC Staff Just Wrote the Private Credit Valuation Checklist

SEC staff's September 28 statement on fair value for private assets reads like a checklist of what private credit has been getting wrong. Here is each item, with the evidence from public BDC filings next to it.

October 10, 2026

Token FMV at December 31: What Your Auditor Will Ask

Pulley shuts down December 8, 2026. Its token customers have a measurement date three weeks later. Five questions the year-end file has to answer, and what breaks when the prior provider disappears.

September 18, 2026

Private Credit's Upside-Down Waterfall

Once a first lien is impaired, every claim beneath it is an option on one enterprise value. Public BDC schedules for June 30, 2026 show junior marks that contradict the senior marks above them.

July 6, 2026

Same Loan, Different Price: Private Credit's Mark Dispersion Problem

The same senior secured loan, marked 27 points apart by regulated fiduciaries on the same day. What private credit marks actually measure — and what would fix it.

February 23, 2026

What NAV Lenders Should Actually Require From an Independent Valuation Report

The NAV lending market is $150B and growing 30% annually. The valuation reports supporting it were designed for auditors, not lenders. Here’s what should change.

January 15, 2026

ASC 820 Portfolio Valuation: What Fund Managers Need to Know

A practical overview of ASC 820 fair value requirements for venture capital, private equity, and private credit fund managers.