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What are the Annual Requirements for Alternative Asset FMVs?

As your custodian, STRATA Trust Company ("STRATA") is required by federal law to obtain and report the fair market value (FMV) or good faith estimate (GFE) of each retirement account we administer on IRS Form 5498 each year. Alternative asset values are not available through public trading exchanges. Therefore, self-directed retirement account owners must generally work with their investment sponsor or issuer (“Sponsor”) to complete this valuation. Unless there are special circumstances, all valuation updates must be submitted to STRATA by April 30, in order to meet the IRS Form 5498 deadline of May 31.

For investors whose IRAs hold cash, publicly traded securities, or exchange-traded precious metals, FMV is easy to determine because market prices are readily available. However, when your SDIRA holds alternative assets—such as private companies, notes, or private equity—determining FMV requires additional care and documentation. In these cases, accurate valuations are not just helpful; they are essential.

Accountholder's role:

STRATA will send a notice to accountholders in February outlining the process. However, no action is typically required for private equity investments, as STRATA will work directly with your investment sponsor to obtain the annual valuation update. Your action is required only if one of the following applies:

  • Sponsor contact information has changed.
    If you are aware that the Sponsor has recently moved or updated their contact details, please have them complete the Information Change Request – Financial Professionals form or provide STRATA with the updated information (address, phone number, and email), so we can update our records.

  • Special circumstances apply.
    If there are special circumstances that may delay the valuation, the Sponsor or accountholder must notify STRATA at InvestmentUpdates@StrataTrust.com and include the expected date the valuation will be provided. Service fees may apply.

  • The Sponsor is unable to provide the valuation.
    If you are aware that your investment sponsor is unable to provide the annual valuation, the accountholder will be responsible for coordinating with a qualified independent third-party to obtain and submit the valuation update.  You may review a list of independent firms here; this information is provided for informational purposes only and does not constitute an endorsement or recommendation of any services by STRATA.

Supporting documentation requirements:

All annual valuation updates must include supporting documentation. Acceptable documentation includes a letter or report that explains the reason for and basis of the valuation and includes a statement of the financial account. The documentation must be signed by one of the following:

  • The LP general partner, LLC managing member, or authorized officer of the issuing entity

  • An independent third party

  • An accounting firm or certified appraiser

  • A CPA or attorney

Note: The party providing the FMV change and/or supporting documentation may not be a disqualified person under 26 U.S. Code § 4975.

Gradient LineAlternative Assets FMV Annual Request Timeline

Annual updates are due to STRATA by April 30, in order to meet the IRS deadline of May 31.

2025 OPA- paper communications (2)

If there is an exception or special circumstance that prevents you from meeting the April 30th deadline, the accountholder must notify STRATA at their earliest convenience at InvestmentUpdates@StrataTrust.com and include the expected date for your FMV. Service fees may apply

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Timeline details: 

  • 2/16 — Sponsor First Request: STRATA will contact the Sponsor and submit an official request for annual valuations as of December 31 (or within 12 months of the last valuation update submitted).
  • 3/16 — Sponsor Reminder: STRATA will send a reminder to the Sponsor if the valuation has not been provided (and they have not notified STRATA that the valuation will be available after April 30th).
  • 4/1/ — Accountholder First Request: If the valuation has not yet been provided and we have not been notified of an extension, STRATA will reach out to the accountholder with specific instructions so they may assist in fulfilling the valuation request. 
  • 4/30 — FMV Deadline: All FMVs must be reported to STRATA in order to meet the deadline for filing IRS Form 5498. Valuations reported after this date may require a corrected IRS Form 5498 to be filed; if so, the $100 Corrected 5498 Fee will apply. 
  • 6/1 — Accountholder FMV Past Due Reminder: If the valuation has not yet been provided, STRATA will send a past-due reminder to the accountholder. The Corrected 5498 Fee may apply. 
  •  7/1 — Late Fee: A Late FMV Fee of $50 will be assessed if the valuation is not received prior to June 30.  STRATA will also attempt to contact accountholders by email or phone to follow up on the late annual valuation. The Corrected 5498 Fee may apply.
  • 9/1 — Custodial Resignation: If the annual valuation has not been provided by this date, STRATA must resign as custodian for the account and distribute the asset in-kind to the accountholder. If a corrected IRS Form 5498 is filed, the fee will apply; the Late FMV fee and Account Closure Fee will also apply. The distribution of the asset(s) will be considered a taxable event, and penalties and additional taxes may be incurred.