Pulley shutdown: What happens to your 409A?

Pulley's shutdown does not invalidate your 409A valuation. A 409A's standing comes from the appraisal that was performed at the time, not from the vendor still being in business, so grants made against a valid Pulley valuation keep the safe harbor protection they already had.

What changes is everything around the report. Your 409A reports are not included in Pulley's standard cap table export, they have to be pulled separately as documents, and after December 8 there is no platform to pull them from. The valuation team that produced them goes at the same time.

This guide covers the dates that matter for your 409A specifically, what to download and when, where your safe harbor actually sits, and what to line up in whatever comes next. Other guides we have related to the Pulley shutdown:

• What happenes to your Pulley cap table, and key dates
• Other Pulley alternatives, if you don't want to transition to Carta

The dates that matter for your 409A

Three deadlines matter, and only one of them is the shutdown date itself

One detail worth noting: Pulley has said it will not assist migrations to any platform other than Carta. Companies moving elsewhere handle the export themselves, which makes the document retrieval step something to start early rather than schedule for the first week of December.

What happens to your existing 409A reports

They stay valid, and your safe harbor stays intact. Safe harbor attaches to the independent appraisal that supported a grant at the time it was made. A valuation firm or platform ceasing to trade later does not reach back and undo that, and options already granted keep their original strike price regardless.

The practical risk is access, not validity. A cap table export does not include executed agreements, board consents, or prior 409A reports. Those are separate documents, and they need pulling separately while the platform is still up.

Companies commonly treat this as a records exercise rather than a migration step, and export a complete set independently of whatever platform decision they make. Where a report is the only evidence supporting a strike price set three years ago, it is worth holding somewhere your finance and legal colleagues can reach it, not somewhere that depends on a vendor relationship.

What you need to collect before December 8:

• Every 409A report, not just the most recent one
• The valuation date and effective date for each
• Board consents approving grants made against each valuation
• Grant agreements tied to those strike prices
• Any correspondence explaining methodology or assumptions

The part founders miss: the valuation team goes too

Pulley performed 409A valuations with an in-house team rather than through an external appraisal firm, and that team goes with the platform. Its own help centre describes a dedicated internal valuations team that has completed over 2,000 valuations, with no third-party firm named.

This matters less for the report you already have and more for the questions that arrive later. When an acquirer's counsel asks how a discount for lack of marketability was arrived at, or an auditor queries a common-to-preferred ratio during an ASC 718 review, the usual answer is to go back to the appraiser. Where the appraiser was the platform, that route closes on December 8.

It is a structural point rather than a criticism of the work. A valuation performed by a platform's own team is still independent of the company being valued, which is what safe harbor turns on. The difference only becomes visible at moments like this one, and diligence is a bad time to discover it.

Companies that want a record of the reasoning commonly note down any outstanding methodology questions now, while there is still someone to answer them.

If your valuation history has gaps

Where grants were made without a valuation supporting them, or records have drifted from what actually happened, a retroactive 409A valuation establishes fair market value as of a past date. The valuation is performed now, dated to the past event it covers, and carries the same analytical rigour as a current one.

One limitation is worth being clear about. A new valuation does not reprice options that already exist. Previously granted options keep their original strike price and are not retroactively adjusted, and only future grants pick up a new fair market value. A retroactive valuation documents what the value was rather than rewriting what was issued. The consequences of skipping a 409A valuation go further into what exposure looks like.

Where grants have already been issued against a gap, tax treatment is genuinely situation-specific. This is territory for your accountant and counsel, and Cake can introduce you to advisors who work with startups on exactly this.

What to line up in your next 409A provider

The shutdown makes a few provider questions concrete that are easy to leave abstract when nothing is forcing the issue.

Whether you can talk to the person doing the work. Methodology concerns raised while a valuation is still in draft are far easier to work through than revisions requested after a report is signed. A valuation you cannot interrogate is one you will struggle to defend later.

"You should have a valuation provider that's willing to hop on the phone and walk you through that. Because again, it's your valuation, they're the service provider. You really need to understand what it is you're signing up for."^{— Steve AllaN, Founder at ALlanytics}

Who actually holds the appraisal

Whether the valuation is performed by the platform itself or by a separate qualified firm, and what that means for continuity if either changes.

What the plan includes before you need it

Founders commonly discover what a subscription covers only when they go to order a second valuation in a year. Safe harbor lasts twelve months or until a material event, whichever comes first, and a funding round, a term sheet, a significant revenue change or an approaching IPO all reset that clock. Companies raising mid-year frequently need two in a plan year. Internal board valuations do not earn safe harbor at all, a distinction covered in the 409A safe harbor guide.

How the timeline is measured

A three-day turnaround measured from complete information is a different promise from three days measured from signature. Preparation is usually the longer part: financial statements, projections, articles of incorporation, term sheets and previous valuations all need gathering, and missing items trigger round trips.

On Cake, 409A valuations are a paid feature of annual plans, with Team and Pro annual plans each including two valuations per plan year, and a draft returned within three business days once everything required has been submitted.