Vanguard Group seems to be on an unstoppable run, with $200 billion added in new assets for the second year in a row, bringing its total assets to $3.5 trillion.

The number could be even bigger, but the Malvern based company is minimizing the value of the shares of Vanguard Group Inc., the company responsible for handling of Vanguard’s funds. The Vanguard Group is owned in part by every Vanguard fund, and therefore by every Vanguard shareholder.

While Vanguard is a private company and you cannot buy Vanguard Group shares on the stock market, SEC rules still make it obligatory for mutual funds to list the complete value of all of the stocks that they own, including the ones owned by a private company.

Vanguard does this with shares of the popular but controversial ride sharing company Uber, as its private shares “are valued by our pricing review committee” using “market valuations of publicly traded peers,” with private transaction prices, according to Vanguard spokesman John Woerth in a recent article for Philly.com.

When compared with its peers, Vanguard could fit between BlackRock, a giant with $5 trillion in client assets, yearly revenues of $15 billion and a market value of $58 billion, and Federated Investments, a more modest company with $350 billion in assets and $900 million in revenues, with a market value of around $3.5 billion.

However, including all of its funds, Vanguard only reports a value of $250 million to the SEC, which represents just a fraction of its size and the volume of cash flow it generates.

Woerth explains that this value represents “capital contributed”, and not current market value.

“Vanguard’s a private company, so we do not think about a ‘mark to market’ valuation, because there is no market for our shares,” he said. While Uber is also a private company, Vanguard differs as its funds give it a market value.

The key point to remember is that while Vanguard has no intention of being sold, it is obligated by a directive between the company and its mutual funds to properly value its assets to take in account the unlikely possibility that the company at some point may be dissolved.