put the onus on fund directors to ensure that funds price their holdings properly. ASRs 113 and 118 remain the primary SEC authority on permissible valuation practices. Recent SEC staff guidance in 1999 and 2001 has focused on funds' obligations to monitor for "significant events" and to determine when market quotations are not "readily available," thereby triggering the obligation to employ fair valuation procedures in determining the value of portfolio securities. Documented and Ratified Valuation Procedures and Valuation Authorizations At first blush, it would seem to be a relatively simple matter to determine a security's price value at a given point in time. In practice, this process is often quite complex and subjective, however. Valuation determinations frequently involve a significant amount of judgment, ranging from the selection of pricing sources to decisions as to when, and on what basis, to override pricing data obtained from those sources. Having formalized documented policies and procedures in place is a fundamental aspect of any consistently applied high-quality valuation process. These policies and procedures help ensure that controls exist around judgments applied to pricing and that the proper control and supervisory structure over such judgments is in place. For example, during examinations of mutual funds, the SEC staff often reviews funds' valuation policies and procedures to validate the presence of this kind of control environment. The importance of adequate supervision and control was highlighted, for example, by the SEC censure of an investment advisor for failing to adequately supervise the pricing practices of one of its portfolio managers. The SEC's order indicated that the advisor had no written procedures to implement the Fund's policy to use bid side market value prices for valuing securities. The firm's practices concerning the daily pricing were insufficient in that they, among other things, gave too much control over the pricing process with little or no oversight by anyone in a supervisory capacity. In addition, there was no procedure in place to alert [the advisor] when bid side market prices were not available. [The advisor] did not independently verify the daily prices provided to [the advisor's] accounting department with the pricing source or any secondary sources.5 Valuation procedures need to cover various dimensions that should be considered in defining the "right" price. Among these are: 11 The parameters for data collection and computation. For example, such procedures should establish criteria for determining when securities are considered to have readily available market quotations and when fair value is required. 5Van Kampen American Capital Asset Management, Inc., Investment Advisers Act Rel. No. 1,525, 60 SEC Docket 1,045 (September 29, 1995).