asset value) and thus misrepresents performance. When a rogue trader engages in mismarking, it allows them to obtain a higher bonus from the financial firm for which they work, where their bonus is calculated by the performance of the securities portfolio that they are managing. Valuation of assets in open-ended funds and hedge funds The NAV of a collective investment scheme (such as a U.S. mutual fund or a hedge fund) is calculated by reference to the total value of the fund's portfolio (its assets) less its accrued liabilities (money owed to lending banks, fees owed to investment managers and service providers, and other liabilities). Calculation of the net asset value for a hedge fund, including the calculation of the fund's income and expense accruals and the pricing of securities at current market value, is a core fund administrator task, because it is the price at which investors buy and sell shares in the fund. The accurate and timely calculation of NAV by the administrator is vital. In 2003, investors in Lancer Group sued hedge fund administrator Citco for allegedly knowingly disseminating "misleading" Net Asset Value (NAV) statements. Citco ultimately informed investors that it was resigning as administrator to Lancer's funds, but did not provide an explanation. While Citco pointed to the fact that it had sought statements from Lancer's board of directors as to the propriety of the valuations, Southern District of NY Judge Shira Scheindlin wrote: "Although these actions demonstrate Citco Group's questioning of the numbers, they could also be interpreted as Citco Group's efforts to shield its own involvement in the process". Ultimately, Citco settled with investors. The case of Anwar v. Fairfield Greenwich (SDNY) is the major case relating to fund administrator liability for failure to handle its NAV-related obligations properly. The defendants settled in 2016 by paying the Anwar plaintiffs $235 million. The court held in the case, prior to the settlement, that "it is reasonable to infer from Plaintiffs' allegations that the Administrators were aware that Plaintiffs would—and did—rely on their statements of the Funds' NAVs that were sent to the investors.... Accordingly, the Court finds that Plaintiffs allege a relationship between the investors and the Administrators that gives rise to a duty of care ...." Businesses Turning to operating companies as opposed to investment companies (mutual funds), in determining whether shares in a public company are a cheap or expensive investment, one tool