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¨C155, 1980¨C1 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¨C2(b).