each asset type held by a portfolio. Pricing date and time (e.g., 4:00 P.M. Eastern time, close of New York Stock Exchange, 4:00 P.M. Central time, previous day close, etc.). Pricing type (e.g., bid versus ask versus mean versus close versus last sale; pricing location (e.g., price from exchange where principally traded, global listings, etc.). Pricing methodologies for over-the-counter (OTC) or illiquid securities with no current price transparency (e.g., matrix pricing, broker quotes, model valuations, etc.). Pricing override/manual price procedures. 11 Specification of the types of reports, automated flagging systems and other controls to be applied to the initial pricing information in order to ensure accuracy and reliability. Further, pricing override and manual pricing procedures should be documented. II Determination of the portfolio management/senior management to whom valuation issues should be reported, as well as specification of the circumstances under which supervisory approval and/or board action is required. II Finally, fair valuation policies, which determine under what circumstances an obtained price still reflects fair value, or whether an alternative pricing mechanism is to be used. Positions Marked by Independent Accounting Agents Valuations are, among other things, used to determine asset manager compensation. Valuations affect both the size of assets under management on which fixed fees are paid as well as reported portfolio performance on which incentive fees may be earned. In order to avoid conflicts of interest in either fact or appearance, pricing responsibility should lie with a team that is removed from and independent of portfolio management and the investment process. In general, segregation of duties in valuation matters is a clear best practice and a necessary but not sufficient condition for an effective internal control environment. Parties that are independent of the investment process such as operations or investment accounting departments, or possibly even outsourced accounting agents, are examples of professional teams that can provide this necessary independent oversight of pricing. It is, of course, critical for the valuation process to have appropriately qualified staff that exhibits a sound knowledge of the financial products to be priced. Commercially available accounting agents with their own internal controls6 can act as the first line of defense for the verification of pricing data. Comparisons of prices across sources, tolerance levels for day-to-day price movements, and comparisons to related securities from the same issuer are some of the sanity checks that can be built into the pricing process of an accounting agent. As we will see in sOften documented in Statement on Auditing Standards No. 70 (SAS 70)/Financial Reporting and Auditing Group (SAS70/FRAG21)-Reviews.