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The Bold is probably not going to help your claim. As others have said though you may or may not have a claim. If you believe you do, talk to a trail attorney with ERISA experience.

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