Remarks by Commissioner Uyeda at the SIFMA’s Private Markets Valuation Roundtable
Summary
Commissioner Mark Uyeda set out his views on private market valuation, emphasising the importance of private capital for economic growth and the complementary relationship between private and public markets. He highlighted the scale of private funds (USD 30.9 trillion RAUM at end-2024) and rejected the notion that private-market growth necessarily harms public markets. Uyeda reviewed legal and regulatory expectations for valuation and disclosure, including the SEC’s Rule 2a-5 (the Fair Value Rule) and Accounting Standards Codification Topic 820, stressing boards’ responsibilities and the role of valuation designees and independent valuers. He also flagged valuation implications arising from President Trump’s executive order on expanding alternative investments in 401(k) plans and encouraged careful consideration of proposals and market data.
Key Points
- Private funds managed USD 30.9 trillion in RAUM in Q4 2024, excluding direct private-company investments.
- Private and public markets are complementary: private markets incubate firms and provide exit liquidity to public markets.
- Accurate valuations and clear disclosures lower the cost of capital and are subject to antifraud provisions of federal securities laws.
- Rule 2a-5 places the board in overall fair-value responsibility but permits a valuation designee and use of independent valuation firms for level 3/illiquid assets.
- Accounting Standards Topic 820 also governs fair-value measurement; closed-end funds must maintain transparent, defensible NAV practices even for illiquid holdings.
- President Trump’s executive order on alternative investments for 401(k)s raises valuation and disclosure challenges if retail access to private assets expands.
- Uyeda welcomes data-driven proposals and cross-regulator engagement to determine appropriate retail exposure to alternatives.
Context and Relevance
This speech matters to fund boards, asset managers, trustees, advisers and plan sponsors. It ties ongoing regulatory tools (Rule 2a-5, Topic 820) to practical valuation governance and to recent policy moves that could broaden retail access to private investments. As policymakers consider allowing alternatives into 401(k) plans, valuation practices, disclosure adequacy and investor protections will be central to whether those changes are workable without increasing investor harm.
Why should I read this?
Quick take: if you run, oversee or advise funds or workplace savings plans, you’ll want to know what the SEC is signalling about valuation and retail access to private assets. Uyeda is clear: valuation rigour, board oversight and sensible disclosure aren’t optional. Read this now to get ahead of potential rule and market shifts.
