Fund Sponsor to Pay $300,000 for Not Following Valuation Procedures
A large mutual fund sponsor agreed to pay a $300,000 fine for failing to follow its own fair valuation procedures. The SEC alleges that the respondent utilized broker and third party pricing service quotes for certain non-agency mbs securities in contravention of its own procedures. According to the SEC, the firmâ€™s procedures required the Fair Value Committee to make a fair value determination when broker quotes differed from transaction prices. The SEC charges that the firm continued to use broker quotes for nearly a month, even though the broker quotes were not accurate or stale. As a result, the Fundâ€™s NAV was misstated for several weeks.
OUR TAKE: This action shows the importance of following your own procedures. The SEC did not specifically charge that the valuations were incorrect or that the procedures were insufficient. Instead, it charged that the respondent failed to follow its own documented procedures.