Identify and document market value aging matrix, including regular intervals at which securities, appropriate to their nature, must be valued Develop any necessary definitions (e.g., stale, observable inputs per security type) Identify steps to follow to prevent, detect, and correct errors in valuation on a timely basis Develop schedule for tolerance testing Conduct testing, document results, review and report any anomalies to senior responsible executive and develop plan to improve Maintain documentation Support Compliance and IIROC examiners Annually prepare review of policy, feed sources, etc. with any recommendations for change for senior executive review> <Compliance under <Enter requisite <Review policy against IIROC Rule 200.1(c) CCO direction> qualifications, Review processes adopted, including methodologies training> Test that the valuation methods identified in the market value aging matrix are consistently applied by security type Review test results Conduct monthly after-the-fact review of price overrides and associated documentation Sample …> Market Valuation Procedures: Permitted Data Sources (update annually): We use reputable data sources that we believe to provide reasonably current, consistent, and reliable securities market values. We identify/review <e.g., with service provider or carrying broker user group> third-party or other primary and secondary data sources used and assumptions for pricing/valuing client securities. <complete and update annually> Data Source For Asset Classes… Comments Listed SVC <x, y, z> <widely-used in industry, Google for complaints> IDC <x, y, z> <List> <x, y, z> OTC <List> <x, y, z> <often may be included with SVC, IDC> <List> <x, y, z> Manual/House Pricing valuation Preferred due to independence and <x, y, z> letter expertise/designation Audited financial Prepared by qualified professional statements with net asset value (NAV) Independent From a law, accounting firm or other recognized accountant or business business valuation professional/firm valuation letter Subscription agreement Confirm experience of underwriter (new issues) Call issuer for latest Note: Do not use in security master; use only for <x, y, z> arm’s-length trade price value as value ages “confirming” <List> <x, y, z>
Identify and document market value aging matrix, including regular intervals at which securities, appropriate to their nature, must be valued Develop any necessary definitions (e.g., stale, observable inputs per security type) Identify steps to follow to prevent, detect, and correct errors in valuation on a timely basis Develop schedule for tolerance testing Conduct testing, document results, review and report any anomalies to senior responsible executive and develop plan to improve Maintain documentation Support Compliance and IIROC examiners Annually prepare review of policy, feed sources, etc. with any recommendations for change for senior executive review> <Compliance under CCO direction> <Enter requisite qualifications, training> <Review policy against IIROC Rule 200.1(c) Review processes adopted, including methodologies Test that the valuation methods identified in the market value aging matrix are consistently applied by security type Review test results Conduct monthly after-the-fact review of price overrides and associated documentation Sample …> Market Valuation Procedures: Permitted Data Sources (update annually): We use reputable data sources that we believe to provide reasonably current, consistent, and reliable securities market values. We identify/review <e.g., with service provider or carrying broker user group> third-party or other primary and secondary data sources used and assumptions for pricing/valuing client securities. <complete and update annually> Data Source For Asset Classes… Comments Listed SVC <x, y, z> <widely-used in industry, Google for complaints> IDC <x, y, z> <List> <x, y, z> OTC <List> <x, y, z> <often may be included with SVC, IDC> <List> <x, y, z> Manual/House Pricing valuation letter Audited financial statements with net asset value (NAV) Independent accountant or business valuation letter Subscription agreement (new issues) <x, y, z> Preferred due to independence and expertise/designation Prepared by qualified professional From a law, accounting firm or other recognized business valuation professional/firm Confirm experience of underwriter Call issuer for latest arm’s-length trade price <x, y, z> Note: Do not use in security master; use only for “confirming” value as value ages <List> <x, y, z>
Securities-Market-Valuation-Policy-and-Procedures-Considerations.docx