&gt; We have not undergone a 409A valuation to determine the current strike price of Clef stock.<p>Isn&#x27;t a 409A valuation required every 6-12 months by the IRS?<p>EDIT:<p>&quot;Section 409A requires the value of stock options be determined “by the reasonable application of a reasonable valuation method” with two caveats: 1) the grant price must reflect material information, often referred to as a value creation event (i.e. the price paid in a recent financing); and 2), the calculation of value must not be more than 12 months old. In practice, private companies pursue 409A appraisals from independent qualified valuation firms either immediately after completion of a financing or other significant financial transaction (e.g. merger or acquisition), or, six to nine months of elapsed time since the prior appraisal, whichever comes sooner (more mature companies tend to pursue appraisals more frequently). The receipt of such an appraisal should provide a safe harbor to employees with regard to a potential tax liability as long as your company is less than 10 years old, you don’t have a liquidity event within 12 months after the option grant or you don’t have put or call rights on your company’s stock.&quot;<p><a href="https:&#x2F;&#x2F;blog.wealthfront.com&#x2F;409a&#x2F;" rel="nofollow">https:&#x2F;&#x2F;blog.wealthfront.com&#x2F;409a&#x2F;</a>