Pulley Is Shutting Down. Who Defends Your 409A Valuation?
Author: Redwood Valuation Content Team
Published: September 18, 2026
On December 8, 2026, Pulley ceases all operations after seven years. Customers are being routed to Carta, with matched pricing for a year and unused subscription time converted to Carta credits. The migration emails make the transition sound simple: log in, confirm, and your cap table moves over.
But moving your cap table to a new platform is not the same as moving your 409A valuation to a new firm. If Pulley issued your valuation, the migration notice leaves a separate question unanswered: when that valuation gets scrutinized, who stands behind it?
A Cap Table Is Data. A 409A Valuation Is an Opinion Someone Has to Defend
Your cap table is a ledger. It records who owns what and can be exported and imported like any other dataset. A 409A valuation is different. It is an independent appraisal of the fair market value of your common stock. That value is the number your option strike prices depend on. It also serves as the basis for your ASC 718 stock compensation expense and is what keeps your option grants inside the IRS safe harbor.
The practical difference is that software can migrate, but a valuation opinion does not. A valuation is only as good as the firm that produced it and can still defend it. When Pulley is gone, the appraisal it delivered does not travel with your cap table, and neither does anyone's obligation to support it.
When the Valuation Gets Challenged, Pulley Will Not Be There
409A valuations get tested well after they are signed—in an audit of your stock compensation, M&A due diligence, a secondary transaction, or an IRS question about a grant. In each case, someone asks how the number was derived and whether it holds up. Historically, those questions went back to the firm that issued the valuation.
After December 8, Pulley is out of business. Migrating your cap table to Carta does not make Carta responsible for a valuation Pulley issued. It is worth asking your migration contact directly whether Carta will stand behind and defend Pulley's prior 409A valuation opinions or only host the cap table data. Those are two very different commitments.
Independent and Bundled Are Not the Same Thing
The next question is what kind of valuation provider you are moving toward. Bundling a 409A valuation with the cap table software you already pay for is convenient, but auditors and the IRS care about independence and rigor, not convenience. Treating the valuation as a checkbox on a software subscription invites more scrutiny, not less, when it matters most: during an audit or a deal.
Redwood is an independent valuation firm focused on 409A, ASC 820, ASC 805, and related valuation work. Our partners sign off on the work, and the valuations are built to withstand audit and diligence.
What Redwood Offers Pulley Clients
If you come to Redwood from Pulley, we take over your account and include audit support for your prior year's valuation as part of the package. If that 409A valuation is later questioned, you have a firm that will stand behind the analysis, not just a data export and a support ticket.
You do not have to accept the default migration path just because it landed in your inbox. Choosing a cap table platform and choosing a valuation firm are separate decisions, and the valuation-firm decision matters more when someone challenges your numbers.
Talk to Us Before December 8
If you are a Pulley customer weighing your options, reach out to Redwood. We will walk through your current 409A valuation, what it will take to support it going forward, and how a transition to Redwood works.