Pulley Shutdown Checklist: 12 Valuation Records to Download Before December 8
Author: Redwood Valuation Content Team
Published: September 24, 2026
Pulley has said it will cease all operations and services on December 8, 2026, when the app will no longer be accessible. However, for customers who do not initiate migration by November 30, Pulley says data access becomes limited after that earlier date, so the practical deadline for complete exports may come sooner. Your first instinct may be to confirm that the cap table is safe. That matters, but the records behind your 409A valuations deserve a separate pass. Those records show how common-stock fair market value was determined for the option grants that relied on the valuations, and you may need them if an auditor, an acquirer, or the IRS later asks how those numbers were derived. This checklist covers the valuation records worth downloading or assembling now, whether you are migrating to Carta, moving to another platform, or still deciding.
The Pulley Dates That Affect Your Valuation Records
Pulley's shutdown FAQ sets out three dates worth putting on the calendar. November 30, 2026, is the deadline to opt in to Carta's migration offer and receive the pricing guarantees and collaborative migration support Pulley describes. To opt in, you must consent to share your contact and contract details with Carta. After that date, Pulley says it offers no guarantee regarding timing, pricing, or disruption to service.
December 8, 2026, is the shutdown date, when Pulley says the app will no longer be accessible.
Pulley says that if you do not initiate migration by November 30, your data will be accessible only in a limited capacity after that date. Pulley has not publicly detailed what that limited access includes. If you are not initiating migration by November 30, treat that date—not December 8—as the practical deadline for any exports you want in full, usable form. Normal app access ends December 8. Pulley describes January 31, 2027 as the end of limited-format access through the app.
Pulley has also said it cannot assist with a migration to a provider other than Carta. If you are not moving to Carta, export the Pulley-hosted records you need while they are accessible. Then use the rest of this checklist to assemble the related company-controlled records.
12 Valuation Records to Download or Assemble
Start with anything that exists only in Pulley or would be difficult to reconstruct after access changes. Other records were sent to Pulley during the valuation process but may also sit in your own email, data room, accounting files, or board records. Gather those company-controlled copies next, then build the grant-to-valuation map once the underlying records are secure. The checklist also includes two records for related purposes rather than as direct 409A inputs. The current cap table helps reconcile a migration, while stock-based compensation reports preserve the company's stock-compensation accounting history. The goal is one complete valuation file that does not depend on any vendor's portal.
The valuation reports
1. Every final 409A valuation report: Download all of them, not only the most recent. Prior reports show how value moved from one period to the next, and a later reviewer comparing grant prices across years will want the full series. Include any appendices or exhibits.
2. The cap table as of each valuation date: A valuation is built on the capitalization that existed on its valuation date. A current export does not show what the analyst relied on two years ago, so keep point-in-time versions where you can.
3. A complete current cap table and equity ledger export: This includes holders, security classes, grants, vesting schedules, exercises, and cancellations. Even if you are migrating, a copy under your own control lets you check that the migrated records reconcile.
The inputs behind each valuation
4. Financial statements and forecasts provided for each valuation: The historical financials and projections you submitted are central inputs. Keep the exact versions used so a later reviewer can see what financial information and expectations were part of the valuation record at the time.
5. Valuation questionnaires and information-request responses: Whatever you submitted to the valuation team to describe the business, its stage, and its outlook forms part of the record of what was known on the valuation date.
6. The financing documents that drove each valuation: Keep the charter and amendments, stock purchase agreements, and SAFE or convertible note terms in effect at each valuation date. Preferred-stock rights and recent financing prices often shape how common-stock value is determined.
7. Secondary sale and tender offer records: Transactions in your own stock can bear directly on fair market value. Keep the pricing, volume, and parties for any secondaries that occurred around a valuation date.
Grants and approvals
8. Board records related to fair market value and option grants: Keep board consents and minutes documenting option-grant approvals and, where applicable, any separate approval or adoption of the fair market value used for those grants.
9. A grant-to-valuation map: For every option grant, record the grant date, the exercise price, and the valuation report or other fair-market-value determination used to support that price. If this does not already exist as a report, build it now while the underlying data is still easy to reach.
10. Stock-based compensation reports: If you used Pulley to support ASC 718 expense reporting, download the reports and the assumptions behind them. Keep them so you can reconcile historical stock-compensation reporting with whatever system you use next.
Support and audit history
11. Correspondence about prior valuations: Keep any exchanges with auditors, investors, or the valuation team about how a valuation was prepared or reviewed, including questions raised in past audits and how they were resolved.
12. Your service and audit-support terms: Pulley described its 409A valuations as coming with free lifetime audit support. Save the terms that applied to your valuations, along with any written confirmation you receive about how support will work after the shutdown. If you migrate to Carta, keep the transition documents as well.
Why Migrating Is Not a Substitute for Your Own Copy
Pulley's FAQ says customers who move to Carta will have their cap table data, documents, transaction history, and equity records migrated. It also says Carta can accept Pulley's existing 409A valuation and fair market value as-is if the customer provides a copy. It further says Carta will support the defense of Pulley's prior 409A valuation work following the transition.
If you are moving to Carta, the transition arrangement is meaningful, but it does not remove the reason to keep your own copies. Pulley's FAQ says customers must provide Carta with a copy of the existing valuation. Relying only on a migrated vendor copy still leaves your valuation history vendor-dependent. Some of the inputs above may not have been stored in Pulley in the first place. We cover what Carta's defense commitment does and does not settle in the article, “Does Carta Defend a 409A Valuation It Didn't Perform?”.
If you are leaving Pulley for a platform other than Carta, Pulley's shutdown FAQ does not describe an equivalent support arrangement for prior valuations. Your own records are therefore the starting point for any future review. Confirm with your new provider who, if anyone, will support prior Pulley valuation work. We look at that question in our article, “who defends a Pulley-issued valuation.”
How to Organize Your Valuation File
A folder per valuation date works well. Each folder holds the final report, the cap table as of that date, the financials and forecasts provided, and the financing documents in effect. Include the relevant board consents or minutes for grant approvals and any separate FMV approval. The grant-to-valuation map and the audit correspondence can sit at the top level, since they span multiple periods.
Keep the file somewhere your company controls and that will outlast any single software vendor. The value of these records often becomes clear years later, during a financing, an audit of stock compensation, or acquisition diligence, when someone reviews grants made long before the current finance team arrived.
Preserving Your Records Is Step One
Downloading your records protects the history. Before access changes, secure the Pulley-dependent exports first. Then gather the company-controlled inputs and approvals and build any missing grant-to-valuation map. After that, reconcile migrated or retained equity data and identify who will support prior valuations if questions arise. The next questions are whether your current valuation can still support new grants and who will handle your valuations going forward. We cover the first in our article, “Does Pulley's Shutdown Invalidate Your 409A Valuation?” and the second in “How to Switch Your 409A Provider (and When You Should)”.
Saved records are only half of the picture. You also need to know what support is available if a valuation is questioned. Redwood is an independent valuation firm specializing in 409A valuations. If your company is moving its valuation work from Pulley, Redwood's package includes help addressing audit questions about the prior year's valuation, along with audit support for the valuations Redwood prepares going forward. This is Redwood's service commitment, separate from the Carta transition arrangement described above.