"Counter-intuitive as it may seem to some plan sponsors, allowing participants to invest in hard-to-value investments through brokerage windows or self-directed accounts does not eliminate their obligation to establish accounting and financial reporting processes for determining their fair value and, for large plans, obtaining enough detail to present the disclosures required by FASB ASC 820. In some cases, third party valuation services may be necessary to assist with documentation of the valuation techniques, assumptions and related inputs, and additional record keepers are required to summarize investment information in brokerage windows in enough detail to comply with the disclosure requirements of FASB ASC 820."  MORE >>