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Valuation of Plan Assets at Fair Market Value

Plan assets must be valued at fair market value, not cost. An accurate assessment of fair market value is essential to a plan’s ability to comply with the Internal Revenue Code requirements and Title I of ERISA. For example, the FMV of assets must be accurately determined to preclude:

  • Prohibited transactions;
  • Exclusive benefit violations under IRC section 401(a);
  • Violations of the section 415 limitation on benefits and contributions;
  • Excess deductions under IRC section 404;
  • Violations of the IRC section 412 minimum funding requirements; or
  • Discrimination violations under IRC section 401(a)(4).

In a profit-sharing, money purchase, or stock bonus plan, the assets’ valuation will determine a participant’s account value, and ultimately, a participant’s distribution. In a defined contribution plan, Revenue Ruling 80–155, 1980–1 C.B. 84 provides that since amounts allocated or distributed to a participant must be ascertainable, plans must value their trust investments at least once a year, on a specified date, and according to a method consistently followed and uniformly applied.

In a defined benefit plan, the valuation of trust assets will determine if the plan is adequately funded and if the plan’s funding assumptions are reasonable. This, in turn, will affect the employer’s deduction and funding status. In a defined benefit plan, IRC section 412 requires yearly plan assets valuations for funding purposes. These valuations must be based on reasonable actuarial assumptions. See Treas. Reg. section 1.401–2(b).