Fidelity invokes the policy "a number of times each year," said David B. Jones, a Fidelity Investments vice president who oversees valuation policy for the company.

In particular, bankers have said that the examiners' application of mark-to-market accounting rules, loan classification guidelines, collateral valuation policies, and loss reserve requirements have contributed to stagnant economic growth.

LAST week, David B. Jones, a Fidelity vice president who oversees the company's fund valuation policies, said that at the time Fidelity decided to use "fair value" pricing, it was aware of the large flows into the Hong Kong fund.

It is active in the area of valuation research and methodology through its subsidiary partner The International Academy of Valuation and Consulting, and hosts its semi-annual International Valuation Conferences to discuss advances in methodology and public valuation policy.

Joseph W. Smith Jr., chief investment officer at Aflac, said it was not directly questioned by the S.E.C. Still, Aflac decided this year to offer more detailed documentation of its investment holdings and valuation policies "to satisfy what we think the S.E.C. would want."