ALFI responds to the IOSCO Consultation Report on Valuing CIS

IOSCO has consolidated the 2007 hedge fund principles and the 2013 CIS valuation principles into a single set of recommendations. We support this direction—ultimately, fewer separate regulations mean clearer expectations for everyone. That said, when it comes specifically to valuation controls, we believe more factors need to be considered. This is the focus of our feedback.

Private assets came up repeatedly throughout the consultation, and rightly so, it is a significant theme. However, we believe further discussion is needed. While “liquidity” appears frequently, we are concerned that the framing leans too heavily on comparisons with traded equity markets. Less liquid assets have their own characteristics, and we would like to see more work done to understand them on their own terms, rather than through the lens of what they are not.

Scaling is the bigger story: getting valuation controls right is foundational to building sustainable businesses in this space.

View the ALFI response.