BBD partner John Braun recently offered his gatekeeper perspective on the evolution of fair value and the SEC's proposed Rule 2a-5 in a Viewpoints column for Fund Board Views.
From the column:
"The dust is still settling from the rule proposal and comment process. And while there is no 
indication as to ultimately what form the rule will take, it seems certain there will be changes, as the SEC has indicated this rule is a priority. We would like to take this opportunity, as auditors and fellow gatekeepers, to point out some striking similarities to audit rules and practice aids that have been implemented relative to the topics of fair valuation methodologies, testing of fair value methodologies and pricing services. These similarities may be useful for fund directors to consider as the structure of their obligations evolves."