Valuation of assets goes to the heart of a hedge fund’s operations.  It forms the basis for management fees, performance fees and employee compensation.  It is also an area subject to considerable SEC scrutiny, especially with regard to illiquid and other hard-to-value assets.  Consequently, effective, accurate and consistent valuation is critical.  A recent program sponsored by the Regulatory Compliance Association described three “pillars” of an effective valuation program.  This article summarizes that program and details the three pillars.  See also “RCA Enforcement, Compliance and Operations 2014 Symposium Offers Insight from Top SEC Officials on Custody, Conflicts, Broker Registration, Alternative Mutual Funds and the JOBS Act (Part One of Two),” Hedge Fund Law Report, Vol. 7, No. 22 (Jun. 6, 2014) (in particular, subsection entitled “Valuation”).