From where did the phrase “as happy as a clam” come?
The phrase “as happy as a clam” is derived from the full phrase “happy as a clam at high water.” Clams are collected during the low tide; during the high tides, they are safe from fishermen.
Internet sources say the phrase was first used in The Bangor Daily Whig And Courier, December 1841: “Your correspondent has given an interesting, and, undoubtedly correct explanation of the expression: ‘As happy as a clam at high water.'” However, https://www.phrases.org.uk says several biographies of General Robert E. Lee state that he used the expression on more than one occasion.
Last June, the Department of Labor (DOL) issued an Information Letter sanctioning the use of private equity investments in asset allocation vehicles offered in defined contribution (DC) plans.
The Information Letter addressed concerns with offering private equity in DC plans—the complex organizational structure, potentially higher fees, illiquidity and complexity of valuations, among other things—with five paragraphs detailing considerations for plan fiduciaries in evaluating and monitoring the investments.
Now, the Defined Contribution Alternatives Association (DCALTA) has published a practical framework to provide plan sponsors clarity on the implementation of daily valuation of private assets. In its white paper, “Daily Valuation of Alternative Assets in DC Plans,” the association suggests a framework with procedural, quality management and governance components. It further explains that:
Daily valuation and pricing can be achieved using an existing approach and in accordance with accounting and legal requirements;
Technical issues such as reporting lag, valuation accuracy and dilutive effects can be handled systematically and fairly; and
Existing audit pathways remain intact, i.e. valuation remains tethered to the net asset value (NAV) reported by the direct manager.
“The framework encompasses 11 positions grounded in principles of fair valuation, ISO [International Organization for Standardization] quality management and effective governance,” says Sheridan Porter, DCALTA member and co-founder of valuation technology firm FEV Analytics. “These elements are important for retirement savers and plan sponsors to have confidence that the procedure used to value these private assets is fair and robust.”