The US Securities and Exchange Commission has made its expectations unmistakably clear, issuing fresh guidance on how registered funds must value private credit assets.
On 26 September 2026, the SEC’s Chief Accountant and the Director of the Division of Investment Management issued a joint statement on the fair valuation of private assets.
Attorneys at K&L Gates LLP describe the statement as significant not so much for breaking new ground, but simply for having been issued at all.
The underlying message, according to the K&L Gates analysis, is that SEC staff are actively looking for robust valuation policies and procedures coupled with material disclosures.
Private credit held by registered funds has grown nearly 60% since 2020, a rapid expansion that has brought both opportunity and mounting regulatory scrutiny to the sector.
Despite that strong growth, private credit has faced redemption and valuation pressure in recent months, prompting senior SEC officials to signal they were watching the market closely.
Chair Atkins and other senior SEC staff have repeatedly noted publicly that the commission is monitoring the private credit situation, and the joint statement appears to be a direct response.
The statement makes clear that valuation models must be calibrated to purchase price and periodically tested against comparable trades, secondary market indications, and relevant credit indices.
A lender’s valuation view must account for what a market participant would consider, including current credit spreads and liquidity conditions at the time of assessment.
The guidance also calls for greater scrutiny of payment-in-kind interest disclosures and non-accrual disclosures, while reminding registrants of the limitations on using boilerplate valuation language.
Funds that hold private fund interests frequently rely on net asset value reported by the underlying manager as a practical expedient permitted under US GAAP, but the practice is optional and subject to conditions.
The staff’s position is that funds should consider all reasonably available information, including relevant secondary-market data, when deploying NAV as a practical expedient.
Funds must also document the basis for using NAV in this way, adding a further layer of procedural discipline that regulators will expect to see in any future review.
The statement signals that the SEC views current private credit disclosures as an area where standards must be raised, not merely maintained at existing levels.