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The SEC charged a business development company (BDC) and three of its officers with overstating the fund's assets during the financial crisis. The fund's asset portfolio consisted primarily of corporate debt securities and investments in collateralized loan obligations (CLOs). According to the order, the BDC's valuation procedures should have been consistent with the requirements of FAS 157, which prioritizes market value over other measures of value. Instead, the fund had treated all of its securities as illiquid, notwithstanding that many of the securities did trade, and valued the