Export your cap table and 409A docs before Pulley shuts down
Export the equity file, request 409A documents, and confirm counsel has the legal record before access closes.
If your cap table is on Pulley, the company is ending service, and December 8 is the last day it will operate. The export is the starting point. A file of shares, option pools, and exercise prices is useful, but it is not the same as the documents counsel needs to defend a grant or explain a valuation.
Pulley was founded by Yin Wu after she sold the Android app Echo to Microsoft in 2015. The company raised more than $50 million from backers including Founders Fund, General Catalyst, Stripe, and 8VC. A funded vendor can still end service, so the continuity plan belongs to the company, not the platform.
During the wind-down, Pulley arranged for rival Carta to take on its customers and sent prospective clients to Carta instead. Carta agreed to assist with customer migration and provide a time-limited promotion. Customers who switch to Carta can retain their existing Pulley price for one year and receive credit for any unused subscription time. The migration offer helps with continuity, but it does not replace the company's own ownership record.
The legal record is the part that survives
A cap table export is a snapshot. It can show who holds what, but it may not show why a grant was approved, what valuation supported it, or which board signed off. The legal record is the set of documents behind the numbers: grant notices, option agreements, board minutes, and the 409A valuation file.
The checklist is the continuity plan
The common failure is exporting the spreadsheet and stopping there. Work through the steps in order, and keep the output where counsel can open it.
- Identify the owner. Name the person who can access the account, approve exports, and answer counsel's questions. Keep a written note of who else has access.
- Export the cap table file. Download the full cap table, including historical grants, exercises, cancellations, and current share counts. The file must open without the platform and show a timestamp for when it was pulled.
- Request the 409A documents. Ask for the valuation reports, board approvals, and related memos. The finished folder contains the valuation date, method, and sign-off.
- Verify option grants and board records. Compare the export against grant notices, board minutes, and the option agreement. Any unexplained gap between what the platform shows and what the company signed needs a fix.
- Confirm counsel has copies. Send the cap table, 409A files, and grant records to outside counsel. Counsel must acknowledge receipt and store the files in the company file.
- Set a migration deadline. Choose a date before access closes and assign the person who will confirm the new system is working. The finished calendar task has a named owner and a final check.
If the account owner is unavailable, the board should name a temporary owner before the deadline. If the company has multiple entities, export each cap table separately and label each file by entity and date in a shared folder. Keep the folder in a place counsel can reach today, not just in one person's control.
A dated migration keeps the record complete
A migration is a records transfer. The new system should show the same share counts, the same grant dates, and the same option terms. If it does not, stop and ask why before the old access disappears.
Do not let the deadline drift to the last day. The migration window is shorter than it looks. If you are moving to Carta, start the migration now. If you are not moving to Carta, the export, the documents, and counsel's copy must exist before access ends. Put the deadline in the board calendar now and assign a person to confirm the file set in writing, with a date.
