Digital assets trade around the clock across many exchanges and OTC desks, which makes fair value measurement a distinct challenge for crypto fund managers. This companion to our full ASC 820 fair value guide focuses on the provisions that affect digital asset valuation, with sample policy language, risk considerations, and answers to common audit questions.
What’s New for 2026
Level 1 vs. Level 2 classification. New guidance explains when an unadjusted quote from an accessible exchange may support Level 1, and why funds relying on aggregated pricing providers often land in Level 2.
Principal market and pricing sources. The guide adds considerations for identifying the principal market across exchanges, using volume-weighted aggregated prices, and setting a consistent pricing cut-off time for markets that never close.
Market participant adjustments. Any pricing adjustments should reflect market participant assumptions, not fund-specific factors such as position size or intent to hold.
Valuation governance and controls. A new section covers selecting pricing sources, identifying stale prices, documenting judgments, and overseeing third-party pricing providers.
Stablecoins. A new FAQ addresses the FASB’s August 2026 proposal clarifying when certain digital assets, such as stablecoins, may qualify as cash equivalents. Comments are due November 19, 2026, and the proposal does not change current U.S. GAAP.
View the Crypto Valuation Guide
What the Guide Covers
Topics include the fair value hierarchy for digital assets, liquidity discounts, SAFTs and ICOs, sample significant accounting policy disclosures, hard forks and airdrops, counterparty and regulatory risk, and FAQs on transaction fees, custodian SOC reports, and audit readiness.
What’s Next
If you have questions about valuation for digital assets or the services Richey May provides to crypto and other alternative investment funds, contact Steve Vlasak at svlasak@richeymay.com.
