Pulley 409A Valuation Review: What the Shutdown Means for Your 409A

Short answer: A Pulley 409A valuation was a solid, fast, reasonably priced option for venture-backed startups already running equity on Pulley. That verdict now matters less than the calendar. If your company holds a Pulley 409A, the report you already have is still usable, but the provider behind it is going away. Your job between now and December 8, 2026 is to secure the records, choose where your cap table goes, and time your next 409A so there is no gap in your ability to grant options.

A disclosure before we start: 409a-valuation.com is itself a 409A provider, so we are not neutral. This review relies on Pulley's own published pages, its shutdown FAQ and press coverage as of September 30, 2026. Where those sources are silent, we say so rather than guess. We are not affiliated with Pulley or Carta, and neither company has reviewed this article.

Is Pulley shutting down?

Yes. Pulley announced on September 16, 2026 that it will cease all operations and services on December 8, 2026. It has not given a public reason. Pulley has partnered with Carta for an assisted migration, and customers must opt in by November 30, 2026. Pulley says limited data access runs until January 31, 2027.

Founder and CEO Yin Wu confirmed the Pulley shutdown in a public post, calling it “not the outcome we hoped for.” TechCrunch reported that the company had raised more than $50 million from investors including General Catalyst, Stripe and Founders Fund. Pulley's homepage now directs prospective customers to Carta and tells existing customers to log in to check their eligibility for the migration offer. These are the dates that matter:

Treat January 31, 2027 as a safety net, not a plan. Some commentators describe the app as inaccessible from December 8, and “limited” access is not defined. Export everything well before the migration deadline.

What Pulley's 409A Service Offered

Pulley built its business as a cap table and equity management platform for venture-backed startups, positioned as a simpler, founder-friendly alternative to Carta. Its 409A valuations sat inside the same product, under the pitch “one platform for your cap table and 409A valuations.” Pulley described its customers as “thousands of ambitious companies from seed to scale.”

On the valuation side, Pulley advertised these features:

• In-house analysts. Pulley said “trusted in-house experts” produced its reports and that its analysts had five or more years of experience.
• A 3 to 5 day turnaround. Faster than most platform providers and well ahead of many traditional firms.
• Audit support. Pulley advertised a “100% audit pass rate” and “free lifetime audit review support.”
• Native cap table data. Share classes, option grants and SAFEs already lived in Pulley, so the valuation started from structured data rather than a spreadsheet export.
• Token valuations. For crypto companies, Pulley also sold token valuations separately, starting at $10,000 for one valuation.

These are Pulley's own claims, and we have not independently verified them. Two deserve context. An audit “pass rate” is not a regulatory measure; auditors review a 409A for reasonableness as part of ASC 718 stock compensation, and a provider's track record says little about your specific file. And “lifetime” support was always tied to the life of the company that offered it, which is now ending.

Pulley's public pages did not name its default allocation method, how it selected volatility or discount-for-lack-of-marketability inputs, or who signed each report. That was typical of the platform category. For how bundled platform 409As compare as a group, see our guide to 409A providers with cap table integrations.

How much does a Pulley 409A valuation cost?

Pulley pricing bundled 409A valuations into plans rather than selling single reports. The Startup plan at $1,200 a year for 25 stakeholders did not include 409As. The Growth plan at $3,500 a year for 40 stakeholders did. Enterprise pricing was custom. Pulley is no longer selling new plans.

That structure matters now for one reason: if you prepaid a Growth plan, part of what you paid for was future 409A work that Pulley will not deliver. According to Pulley's shutdown FAQ, customers who opt in to the Carta migration get their current Pulley pricing honored for the first year and credit for any unused prepaid balance. Customers who move elsewhere should ask Pulley support directly how unused prepaid balances are handled, because the FAQ describes the credit only in the context of the Carta offer.

For budgeting the next valuation, compare quotes against our 2026 409A valuation cost benchmarks. As a reference point, Pulley's $3,500 Growth plan covered cap table software and 409As together; a standalone 409A for a seed or Series A company commonly costs a fraction of that, while a cap table subscription is a separate line item.

Is my Pulley 409A still valid after the shutdown?

Yes, in most cases. A Pulley 409A performed by a qualified independent appraiser can support grants for up to 12 months from its valuation date, provided no material event has occurred since. A vendor closing does not change the value of your stock, so the Pulley shutdown does not by itself end that window.

The rule comes from Treasury Regulations Section 1.409A-1(b)(5)(iv)(B)(2)(i). A value set by a qualified independent appraisal, as of a date no more than 12 months before the grant, is presumed reasonable. The IRS can overcome that presumption only by showing the valuation or the method was grossly unreasonable. The presumption depends on how the valuation was done and when, not on whether the appraiser is still in business.

The window closes early if something material happens. A priced round, a signed term sheet, an acquisition offer, a large new contract or a sharp drop in results can all make an older valuation unreliable, because the regulations do not allow reliance on a value that fails to reflect information available after the valuation date that materially affects value. Our guide to material events and your 409A covers what counts. Carta has said, per Pulley's FAQ, that it will accept Pulley's existing 409A and fair market value as-is for migrating customers.

What changes is not validity but defensibility. A 409A is usually tested long after delivery: by your financial statement auditor reviewing ASC 718 expense, by an acquirer in diligence, or by SEC staff reviewing pre-IPO grants. Those reviewers ask the appraiser questions. If the appraiser no longer exists, you need the report and its supporting schedules in hand, and a new appraiser willing to stand behind the history. Our guide to audit-defensible 409A valuations explains what reviewers look for.

What to Download from Pulley Before December 8

Export a complete copy of your equity records now, even if you plan to migrate to Carta. An assisted migration moves data into a new system; it does not give you an independent archive. Store the export where finance and legal can both reach it. For 409A purposes, the list is:

1. Every 409A report, not just the latest. Your next appraiser and your auditor will want the history to reconcile changes in value over time.
2. Supporting schedules and exhibits. Waterfall, allocation and discount calculations, if Pulley made them available, are what an auditor asks for first.
3. Board consents approving each valuation and each grant. These tie each option's exercise price to a specific report.
4. The full option ledger. Grant dates, exercise prices, vesting schedules, cliffs, acceleration terms, exercises, cancellations and repricings.
5. Convertible instruments. Every SAFE, convertible note and warrant, with caps, discounts and conversion terms.
6. Forms 3921 and Rule 701 records. Filed ISO exercise statements and any Rule 701 disclosures.
7. Transaction history. Secondary sales and tender offers, which appraisers weigh as indications of value.

Then reconcile the export against your source documents. Platform ledgers are only as accurate as the data entered, and a migration is when a missing SAFE or an unrecorded board consent tends to surface. Fixing it now is far cheaper than fixing it when your next 409A is built on the wrong share count. Our guide to how your cap table drives your 409A explains which errors move the number.

Your Options for the Next 409A After the Pulley Shutdown

The decision has two parts: where the cap table lives, and who performs the 409A. Pulley bundled them, but they do not have to stay bundled. The table compares the four realistic paths. It compares service models, not providers; for a ranking by stage, see our guide to the best 409A valuation providers.

The Carta path is the lowest-effort option, and the audit-defense commitment for prior Pulley work is valuable. Read the terms closely: year-one price protection ends, BPM notes the migration requires quarterly or annual billing, and you are moving into the platform Pulley was built to compete with. Our Carta 409A review covers what its valuations include.

The non-Carta paths mean exporting and rebuilding your records yourself, with no vendor-assisted migration from Pulley. If you are leaving the Pulley ecosystem partly to avoid Carta, our guide to the best alternatives to Carta for 409A valuations lays out the options, and our Eqvista 409A review covers one of the low-cost bundles.

How to Time Your Next 409A Around the Migration

Changing appraisers is not itself a material event, so the Pulley shutdown does not force an immediate new valuation. Three situations do change the timing:

• Your Pulley 409A is more than about nine months old. Order the next one now. Onboarding a new provider during a migration takes longer than a routine refresh, and you do not want the 12-month window to lapse before a planned grant.
• You have raised money or signed a term sheet since the Pulley valuation date. The old report likely no longer supports grants regardless of the shutdown. Our guide to refreshing your 409A after a funding round covers the timing.
• A Pulley valuation is still in progress. Get a written delivery date from Pulley support. If it is not comfortably before December 8, 2026, plan to reorder elsewhere.

Whoever performs the next valuation, ask for a reconciliation to the Pulley report: why the value moved, which inputs changed, and whether the methods differ. That paper trail is what lets an auditor follow the change without asking questions only Pulley could have answered. Plan backward from your next board meeting; our guide to 409A valuation turnaround time shows where the days go.

Pulley 409A Strengths and Limitations in Hindsight

For readers who used Pulley, or who are choosing a replacement, the strengths are worth carrying forward as requirements:

• Speed. A 3 to 5 day turnaround set a high bar for platform providers.
• Clean data flow. A valuation built directly on a maintained cap table avoids the transcription errors of spreadsheet handoffs.
• Predictable cost. Bundling 409As into the Growth plan removed the temptation to stretch an old valuation past a financing to save a fee.

The limitations were common to the category and the shutdown has made them concrete:

• Provider risk. A 409A bundled with software depends on the software company's survival. When it closes, the valuation team and its audit support go with it.
• Lock-in. With the cap table and valuation in one plan, leaving either meant leaving both, and now every customer has to move both at once.
• Limited methodology detail. Public materials did not name the signing appraiser or default methods.

When you pick the next provider, ask for the name and credentials of the appraiser who will sign, independence representations, a redacted sample report at your stage, and how you would get your full history out if you leave. Our guide on how to hire a 409A valuation consultant expands on each, and our 409A provider review roundup summarizes how other providers are rated.

The Bottom Line on a Pulley 409A

The conclusion of this Pulley 409A review is that the service was fast, well integrated and fairly priced for companies on the Growth plan, and that none of it will exist after December 8, 2026. A completed Pulley 409A remains usable for up to 12 months from its valuation date if nothing material has changed. Download every report and supporting record now, decide by November 30, 2026 whether to take the Carta migration, and schedule your next valuation so there is no gap in coverage.

Whichever provider comes next, remember who carries the risk. An option granted with an exercise price below fair market value on the grant date can fail the stock right exclusion in Treasury Regulations Section 1.409A-1(b)(5)(i) and be treated as deferred compensation. If it does not comply with Section 409A, the option holder faces income inclusion as the option vests, an additional 20% federal tax and a premium interest charge under Section 409A(a)(1), and some states, including California, add their own tax. Our guide to 409A penalties walks through the consequences, and our 409A safe harbor guide explains how a qualified, independent appraisal protects your team.

This article is general information about valuation practice and provider selection, not legal, tax or accounting advice. It is not affiliated with or endorsed by Pulley or Carta. Descriptions of Pulley's services, pricing, turnaround, claims, shutdown timeline and migration terms reflect Pulley's publicly available materials and press reports as of September 30, 2026, and may change; confirm current terms directly with Pulley and Carta. Whether a particular valuation qualifies for a presumption of reasonableness under Treasury Regulations Section 1.409A-1(b)(5)(iv)(B) depends on the specific facts. Consult your own counsel, tax advisor and auditor about how IRC Section 409A applies to your company's equity grants.