The rules for “Valuation at Market©” are based on the IPO CLUB LLC proprietary methodology: price inputs are derived from the 10 most active secondary brokers during the quarter, as well as publicly available information, such as federal filings (e.g., Form D), state filings (e.g., amendments to certificates of incorporation, limited offering exemption notices, employee plan exemption notices), and company disclosures (e.g., press releases, other public statements). The calculation model is based on actual or derived prices of preferred stock and common stock, which are validated by the fund manager. Corporate actions, such as bankruptcies, stock splits, reorganizations, mergers and acquisitions, and spinoffs, are monitored on a daily basis. Index values are calculated for each calendar month, but distributed on a quarterly basis, before the last day of January, April, July, and October.