Leaderboard

It isn't clear to me why you can't talk to the client and give them this option: 1) The client can go through the positions and look up the closing costs and put them in this spreadsheet with the positions listed. You will use that for the values. In short make the client do the work. 2) The client can agree to pay you for the work outlined above. If the client refuses to do both and wants you to use a value from an older time period get that instruction in writing from them and do what the plan administrator tells you to do. You need to explain that you don't think at is the correct way to do . I have done what I have outlined above in these types of situations (but not the exact same set of facts) many times. You are not obligated to give your services away for free. And while I get that at times it is cheaper to give a client what they want then replace them if they leave I see no reason why you assume you have to be a "door mat". For what it is worth I agree the tax implications are small to none but it still should be the plan administrator authorizing using an old value if that is the decision. edit was to fix minor typos

Can you ask the fund house for the value on the date journaled?

^if you're serious, google: Borzi

Yes, I would be concerned. It isn't as bad as other designs I have seen, but I would make sure the client understands your concerns. Also, make sure the clients attorney is also on board unless you are prepared to defend the formula yourself. A few years ago a lot of people were basing cash balance credits on a "special bonus". The IRS accepted this for a few years, then they stopped accepting it and started to challenge it. They even went as far as revoking previously issued determination letters. If you have a determination letter for the plan you are in a much stronger position, but even then, I would be a little concerned. Also, just because I would be concerned doesn't mean it isn't accepted in certain circles and hundreds of people are doing it.