Remarks by Commissioner Uyeda at the SIFMA’s Private Markets Valuation Roundtable

Summary

Commissioner Mark T. Uyeda addressed the role of private capital markets in supporting economic growth and innovation, emphasising that private and public markets are complementary rather than zero-sum. He highlighted the scale of private funds ($30.9 trillion RAUM as of Q4 2024) and noted that robust, materially accurate valuations and disclosures reduce the cost of capital for both operating companies and private funds.

Uyeda reviewed regulatory expectations for valuation practices, including the Investment Company Act’s Section 2(a)(41) and Rule 2a-5 (the SEC’s Fair Value Rule), the role of valuation designees and independent valuation firms, and the relevance of ASC Topic 820 for fair-value measurement. He stressed the need for strong, risk-based processes with oversight, testing and documentation for hard-to-value assets and NAV calculations.

He also discussed the policy implications of President Trump’s executive order on alternative investments in 401(k) plans, noting the potential to broaden retail access to alternatives (venture capital, private credit, infrastructure, digital assets) with appropriate guardrails and valuation safeguards.

Key Points

Private markets are large and growing (c.$30.9tn RAUM in Q4 2024) and complement public markets by incubating companies and providing exit pathways.
Accurate valuations and transparent disclosures in private markets reduce cost of capital and protect investors across both private funds and operating companies.
Registered funds must follow Section 2(a)(41) and Rule 2a-5: boards determine fair value, can appoint valuation designees, and may rely on independent valuation firms for level 3 assets.
Valuation practices should be risk-based, documented, tested and overseen; ASC Topic 820 also guides fair-value measurements for restricted and illiquid securities.
NAV remains a key reference for closed-end funds, especially around liquidity events, activist pressure or tender offers, even where shares trade at premiums or discounts.
The 2025 SEC Division of Examinations prioritised accuracy in fee calculations, allocations and valuation of illiquid assets—areas that affect investor protections and costs.
President Trump’s executive order on alternative investments could expand 401(k) access to alternatives; Uyeda supports careful evaluation, data review and appropriate guardrails for retail exposure.

Author’s take

Punchy and to the point: Uyeda frames valuation as the connective tissue between private capital expansion and investor protection. If you care about fiduciary duty, NAV integrity or the policy push to democratise alternatives, the details here matter — they shape how regulators and market participants will balance access with safeguards.

Why should I read this?

Short version: this is where policy, pensions and private money collide. Uyeda explains why valuation rules and better disclosures actually protect investors and lower costs — and why the new push to let 401(k)s buy alternatives will hinge on valuation and guardrails. Fast read, plenty of practical implications for fund managers, advisers and trustees.