does not necessarily follow that the mark was "wrong." In fact, given the width of the confidence interval, the mark may still have been appropriate. The policy issues raised here are how to appropriately price an asset that has a fuzzy market consensus view as to its value. For liquid markets, price and value tend to converge on the same number. Hence, pricing feeds received from numerous vendors should yield the same result. This condition does not hold for less liquid markets which are characterized by a divergence between price and value. In such cases, there is a need for judgment to determine the most appropriate pricing given all relevant factors. As we will show later, such judgments are most credible when they are applied by professionals who are independent of the portfolio management process in both fact and appearance. In establishing valuation and pricing policies, it is important to review best industry practices, industry regulation, and government regulation. The long established and highly regulated mutual fund arena is a very good starting point for reviewing valuation policies. Even if for other market segments such as hedge funds and institutional separate accounts there is less formal guidance, the mutual fund-related rules could help define the general framework of best practices across all investment management products. The fundamental rules governing valuation of portfolio securities for mutual funds are set forth in Section 2(a)(41) of the Investment Company Act of 1940 (the 1940 Act), which defines the "value" of fund assets in terms of a simple dichotomy: 11 Securities "for which market quotations are readily available" are to be valued at such quotations or prices. II All other securities are to be priced at "fair value as determined in good faith by the board of directors." Various SEC regulations reiterate these statutory standards. In 1969 and 1970, the SEC became concerned about the appropriateness of fund valuation practices and issued accounting releases that offer guidance on proper valuations. ASR 1134 principally addresses valuation practices with respect to restricted securities, but also offers guidance on certain other aspects of the valuation process. Then, ASR 118 deals with the use of fair value methodologies to price securities and sets forth the general principle that the fair value of securities "would appear to be the amount which the reasonable expect to receive upon their current sale." Under ASR 118, funds were instructed "generally" to use the last quoted sales price at the time of valuation. For securities that are listed on more than one exchange, ASR 118 indicates that funds should use the last sales price from the exchange on which the security is principally traded and that the last sales information from the other exchanges should be used only when there are no trades reported on the primary exchange on that date. When there is no quoted sales information, ASR 118 contemplates the use of bid and ask prices quoted by broker-dealers. Best practice is to obtain quotes from multiple dealers "particularly if quotations are available only Accounting Series Release No. 113, Investment Company Act Rel. No. 5,847 (1937-1982 Accounting Series Release Transfer Binder), Fed. Sec. L. Rep. (CCH).