However, there may be circumstances where it may be more appropriate to value the asset
using appropriate valuation techniques if the use of the most recent market price is not
appropriate, such as in the case of a security that has not traded frequently, or is otherwise
illiquid and hard-to-value.
14
As stated above, the CIS also should consider whether specific
skills and systems are necessary in considering valuation issues regarding hard-to-value
assets.
15
Frequently, hard-to-value assets tend to be illiquid (with a very limited or no secondary
market). In this respect, a CIS portfolio manager should monitor the liquidity in markets in
which the CIS is invested as part of a liquidity management policy. The more illiquid such
markets are, the more robust the valuation process may need to be. Similarly, as part of risk
management, where appropriate to the applicable jurisdiction and CIS, the policies and
procedures could consider valuation practices in normal and stressed market conditions.
When taking into account the opinion of a third party (e.g., a valuation agent or an external
rating), the Responsible Entity should assess the methodology and parameters on which such
opinion was produced in considering whether the opinion is suitable.
Principle 3: The valuation policies and procedures should seek to address conflicts of
interest.
Potential conflicts of interest regarding valuation of a CIS’s portfolio assets can arise in a
number of ways. For example, while the Responsible Entity remains ultimately responsible
for overseeing the implementation of the CIS’s valuation policies and procedures, in some
cases the CIS operator can have input into the appropriateness of a particular valuation. For
example, in cases involving complex or illiquid assets that are hard to value, the CIS operator
may in practice be the most reliable or only source of information about pricing for a particular
asset. However, the CIS operator has a conflict of interest with regard to the CIS’s valuations,
particularly as its fees are calculated based on the CIS’s assets under management. As a result,
the CIS operator has an incentive to overvalue CIS assets to increase its fees.
Conflicts of interest can be addressed in a number of ways. For example, reviews of valuations
that are independent of the CIS operator can help to ensure that the valuations of assets have
been determined fairly and in good faith, and protect investors as CIS must redeem and
14
For example, in some jurisdictions, certain securitized and structured finance instruments (SFIs) are
considered as hard-to-value assets. In these jurisdictions, in valuing such assets (such as
collateralized debt obligations, residential mortgage-backed securities and other types of asset backed
securities), marking the SFI to model implies an appropriate analysis of its underlying assets and
structure, including collateral. IOSCO previously examined good practices for investment managers
when investing in SFI see Good Practices in Relation to Investment Managers’ Due Diligence When
Investing in Str
uctured F
inancial Instruments, Final Report, IOSCO Report, 29 July 2009, available at:
htt
p://www.iosco.org/library/pubdocs/pdf/IOSCOPD300.pdf.
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For example, an appropriate valuation technique could include, if consistent with the applicable
jurisdiction’s regulations, valuing the asset using a marking-to-model technique that takes into account all
of the relevant information, including market data. For CIS that use models, the policies and procedures
should consider how to update the model over time.