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How to submit an annual FMV for your assets

For every non-publicly-traded asset in your IRA, Retired.com needs a current-year Fair Market Valuation each year.

How to submit an annual FMV for your assets

For every non-publicly-traded asset in your IRA, Retired.com needs a current-year Fair Market Valuation each year. This article walks through what to submit, what documentation to include, and what valuation sources are typically accepted by asset type.

What you'll need

  • A current-year Fair Market Valuation from an independent third-party source for each non-publicly-traded asset in your account.

  • Supporting documentation (the appraisal, broker opinion, sponsor statement, or similar) that establishes the valuation methodology and date.

  • Access to the Retired.com platform or contact information for the Service Team.

Steps / Explanation

Fair Market Valuation (FMV) submissions follow an annual cycle. For background on what FMV is, why it matters, and the broader responsibility split, see "What is Fair Market Valuation (FMV) and why it matters". This article focuses on the operational mechanics of getting your valuations to Retired.com each year.

What needs to be submitted

You need to submit an FMV for each non-publicly-traded asset in your account. Publicly traded securities (stocks, ETFs, mutual funds, bonds, listed cryptocurrencies on supported exchanges) are valued automatically using year-end market data and require no submission from you.

Non-publicly-traded assets that typically require submission include:

  • Real estate (direct ownership and partial interests)

  • Private equity and private placements

  • Promissory notes and private loans

  • LLC interests and Checkbook IRA structures

  • Precious metals held in custodial storage (when not priced through the storage facility's standard reporting)

  • Privately held cryptocurrency or digital assets not on the platform's standard pricing feeds

  • Any other asset for which Retired.com does not have an automated year-end valuation feed

If you're not sure whether a specific asset requires submission, contact the Service Team to confirm.

How to submit

Retired.com supports two paths for FMV submission:

  1. Through the Retired.com platform. Each non-publicly-traded asset has an annual FMV submission field in your account portal. You enter the value, upload the supporting documentation, and confirm.

  2. Through the Service Team. For complex submissions — multiple assets, unusual asset types, or supporting documentation in a non-standard format — the Service Team can accept submissions directly. Contact the Service Team to initiate.

Either path results in the same outcome: the FMV is recorded in the account, used in your year-end Form 5498 filing (Box 5), and retained in the audit trail.

What documentation to include

For each submission, you should include the following supporting information:

  • The valuation amount as a specific dollar figure (not a range).

  • The as-of date for the valuation — typically December 31 of the reporting year, or a reasonable proximate date.

  • The source of the valuation — appraiser name, sponsor name, broker, or other valuation professional.

  • The methodology used — comparable sales, NAV, discounted cash flow, sponsor-stated value, etc.

  • The supporting document itself — appraisal report, broker opinion letter, K-1, sponsor capital account statement, etc.

The IRS does not require that you submit the full supporting document to Retired.com — but Retired.com may request it for record-completeness, and you should retain copies in your own records regardless. See "Your recordkeeping responsibilities as an SDIRA holder" for the broader recordkeeping framework.

Acceptable valuation sources by asset type

The right source of valuation depends on the asset. Below are the standard sources for common SDIRA asset categories. None of these is the only acceptable approach — what matters is that the methodology is recognized, independent, and current.

Real estate

  • Full appraisal from a licensed real estate appraiser. Most authoritative but also most expensive.

  • Broker price opinion (BPO) from a licensed real estate professional. Less rigorous than an appraisal but typically acceptable for smaller positions or annual reporting.

  • Comparable-sales analysis documenting recent transactions of similar properties in the same area. Most useful where comparable sales are readily identifiable.

  • Property assessor's appraisal — county tax-assessor values are sometimes accepted, but they often lag the market and may understate value. Use with caution.

For residential income property, a year-end statement of rents, expenses, and stabilized income can supplement the valuation.

Private equity and private placements

  • Sponsor-issued NAV statement — most funds and private investments issue periodic NAV statements that reflect the manager's current valuation.

  • K-1 capital account balance — for partnership investments, the K-1's reported capital balance can serve as a baseline (though it reflects tax-basis accounting rather than fair value in some cases).

  • Most recent transaction price for the security — if there has been a recent round of capital raising or a secondary transaction at a defined price.

  • Fund administrator's audited financial statement — for funds that produce audited financials, the audited NAV is the strongest source.

For very illiquid or hard-to-value private positions, engaging a qualified appraiser specializing in private-company valuation may be appropriate, particularly for high-value holdings.

Promissory notes

  • Principal balance plus accrued interest as of the valuation date, for performing notes.

  • Adjusted value for notes that are delinquent, in default, or impaired — typically a discount to the principal balance reflecting collection risk. Document the basis for the discount.

  • For convertible notes or notes with equity features, additional valuation work may be needed to reflect the embedded option's value.

Precious metals

  • Spot price at year-end, multiplied by the documented quantity and type of metal, sourced from a recognized commodity pricing feed (e.g., LBMA, COMEX).

  • Statement from the IRS-approved custodial storage facility confirming quantity held and applying their standard year-end pricing.

Cryptocurrency

  • Year-end closing price from a recognized exchange (Coinbase, Kraken, or similar — typically the exchange where the assets are held).

  • For tokens with thin liquidity or pricing variance across exchanges, document the source and apply consistent methodology year over year.

LLC interests (Checkbook IRA structures)

  • NAV of the LLC as of year-end, calculated from the LLC's books (assets minus liabilities, with the IRA's ownership percentage applied).

  • For LLCs holding real estate, private investments, or other assets, the FMV is the LLC's underlying assets valued individually using the methods above, then aggregated.

Special cases

A few situations that come up regularly:

  • Multiple assets in one account. Submit a separate FMV for each non-publicly-traded asset. Aggregate values are not acceptable — Digital Trust files individual asset values that roll up to a total account FMV.

  • Asset acquired mid-year. The acquisition price is generally acceptable as the FMV for the year of acquisition, provided the acquisition was at arm's length and recent enough to remain current.

  • Asset sold or fully exited during the year. No December 31 FMV is needed for an asset that's no longer in the account. The proceeds (now cash) are part of the account's cash balance.

  • Asset valued in foreign currency. Convert to USD using the year-end exchange rate. Document the exchange rate source.

  • Asset with disputed or pending valuation. Submit the best available value and document the dispute. If the dispute is material, contact the Service Team and a tax advisor for guidance before the deadline.

We recommend consulting a tax advisor or attorney for guidance specific to your situation, particularly for high-value or unusual valuations.

Common questions

Can my Account Representative or the Service Team help me determine my FMV?
No. Neither Retired.com nor Digital Trust, the custodian for your account, produces or evaluates valuations — that is explicitly outside the custodian's role. The Service Team can clarify the submission process, accept your documentation, and answer questions about formatting and deadlines, but cannot tell you what a specific asset is worth.

What if my asset hasn't changed in value year over year?
You still need to submit a current-year FMV — even if the value is identical to last year. Document the methodology that produced the same value (for example, "year-end NAV from sponsor statement, no change from prior year"). Carrying forward last year's number without re-verifying is not compliant.

Do I need a new appraisal every year for my real estate?
Not necessarily a full new appraisal, but you do need a current-year valuation. Many SDIRA holders rotate among appraisal, BPO, and comparable-sales analysis across years — a full appraisal every few years, with BPO or comparable-sales updates in the intervening years. Document the methodology used each year.

What if I submit a value and later realize it was wrong?
Contact the Service Team. If the FMV was already filed on Form 5498, a corrected 5498 can be filed. The sooner the correction happens, the simpler the process — particularly if the original filing affected an RMD calculation. See "FMV deadlines and what happens if you miss them" for the broader correction process.


Need more support? Contact our Service team

Select "Start a Conversation" from the Chat menu or call us at 1-800-RETIRED

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