IDAs with LLC investments

[Lori Foresz]

I think I know the answer but want to be sure.

If an IDA participant in a small plan has an LLC investment, does this mean that 100% of the assets are not in qualifying assets and long form must be filed. The LLC is held in custody by the IDA custodian (an RFI) but the LLC does not have a readily determinable market value. I was hoping maybe there was an exception for participant directed IDA investments that would allow us to continue to be eligible to file an SF.

Thanks

[Bird]

Looks like there is a distinction between "eligible plan assets" (those with a readily determinable FMV allowing you to file an SF) and "qualifying plan assets" (those that satisfy the requirements so a plan audit is not required). There is a caution for line 6b that makes that point; reading in part:

"Holding all the plan’s investments in “qualifying plan assets,” however, would not necessarily satisfy the conditions for filing the Form 5500-SF. For example, real estate held by a bank as trustee for a plan could be a qualifying plan asset for purposes of the small pension plan audit waiver conditions but it would not be an “eligible plan asset” for purposes of the plan being eligible to file the Form 5500-SF because real estate would not have a readily determinable fair market value..."