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I explained that in my post, or at least made assumptions - the val is being done by an accountant, so it starts out on the (way) back burner. Then the sponsor and accountant are probably making decisions on contributions as late as possible (October) and not finalizing the val until then. So they think this particular participant's account is unknown until then when in reality it can be determined much earlier by allocating gains or losses when determined; additional allocations of contributions are not relevant to this participant's account. As suggested by JackS, they could pay the 2018 balance now and gains later and avoid some of that. If it's a large account relative to the rest of the plan, I would always recommend setting aside an estimated amount of cash so that market fluctuations (specifically a downturn) does not affect other participants. If the market goes up, the participant is SOL...a case might be made for some kind of fiduciary liability but it wouldn't be worth the effort/cost to pursue it. Bottom line, you are right that it shouldn't take so long and a lot of headache and hassles can be avoided by better administration.

If it is everybody in their own group, sure.

and back door Roths are a consideration.

Thank you all SO MUCH! We will get our act straightened out now that we know what we need to do. Everybody here is busy applying for PTINs this morning. This was a lot of help.

I agree with this, but I think an "or" is missing (I added in brackets). If you're sure you had gains for 2019, and in all likelihood you did, then pay the 100%. As a side note, it really shouldn't take until October to determine this person's account balance. He's not getting a contribution, and that is probably why your val isn't completed until October - so that contributions are allocated are included in the val. But the gains or losses should be able to be determined and allocated much sooner than that. But if your plan is being run by your accountant, then it is on hold until s/he's done with tax season...and...you didn't ask for this with your fairly innocent question, but if your plan is being run by your accountant, there are probably lots of things wrong with the way it is being run. That is based on experience taking over plans that were run by accountants.