FMV deadlines and what happens if you miss them
The annual Fair Market Valuation submission has a real deadline, and missing it has real consequences — particularly for accounts subject to Required Minimum Distributions. This article covers Retired.com's annual FMV deadline, what happens when a submission is late or missing, and how to remedy a missed year.
Steps / Explanation
Each year, the Internal Revenue Service (IRS) requires custodians to file Form 5498 by May 31 reporting the prior year's December 31 Fair Market Value of every IRA. To meet that filing deadline, Digital Trust, the custodian for your account, needs your Fair Market Valuation (FMV) submissions for non-publicly-traded assets earlier in the year — collected through the Retired.com platform, typically by an internal deadline well before May 31.
For background on what FMV is and why it matters, see "What is Fair Market Valuation (FMV) and why it matters". For the submission process, see "How to submit an annual FMV for your assets". This article covers timing and consequences.
Retired.com's annual FMV deadline
Retired.com publishes an annual FMV submission deadline that gives enough lead time to process submissions, follow up on incomplete documentation, and enable Digital Trust to file Form 5498 by May 31. The specific deadline date is communicated each year through the account portal and direct outreach — typically falling in the first quarter of the year following the reporting year.
Why earlier than May 31? Because the custodian needs time to:
Receive and acknowledge your submission.
Request additional documentation if the submission is incomplete.
Apply the value to the account's year-end position.
Generate, review, and file Form 5498 with the IRS by the IRS deadline.
If your submission lands on May 30, there is no time for any of the above. The internal deadline is what makes the IRS deadline achievable.
What you'll typically see in the lead-up
The standard cadence:
Notification in January or early February announcing the deadline and listing the assets in your account that require FMV submission.
Reminder as the deadline approaches for any asset that hasn't yet been submitted.
Deadline date for FMV submission to Retired.com.
Follow-up requests if a submission is missing supporting documentation or contains an obvious error.
Filing of Form 5498 by May 31, using submitted FMVs for non-publicly-traded assets and automated year-end prices for publicly traded ones.
Watch for the notification email each year and submit promptly — particularly for assets that require third-party documentation (appraisals, sponsor statements) that takes time to obtain.
What happens if you miss the deadline
Missing the FMV deadline has cascading consequences, ranging from administrative to financial.
1. Form 5498 may file with a placeholder or last-known value
If no current-year FMV is on file by the time Digital Trust prepares Form 5498, the form will still be filed — the IRS deadline is non-negotiable. Digital Trust's options depend on what is available:
Last-known FMV carried forward. For an account that submitted in prior years, the prior year's FMV may be reported with a notation that it is not current.
Cost basis as a placeholder. For an asset acquired recently, the acquisition cost may be used.
Zero or "value not determined." In rare cases where neither a prior value nor a recent acquisition is available.
None of these is a correct FMV. Each carries downstream consequences.
2. Inaccurate Required Minimum Distribution (RMD) calculations
For Traditional, SEP, and SIMPLE IRA holders subject to RMDs, the prior-year December 31 FMV is the denominator for the current-year RMD calculation. An understated FMV produces an understated RMD; an overstated FMV produces an overstated RMD.
The IRS does not accept "the FMV was wrong" as a defense against the 25% excise tax on a missed RMD shortfall (reduced to 10% if corrected within two years under the SECURE 2.0 Act). If a missed FMV produces an RMD calculation that turns out to have been short, the excise tax may still apply — and the calculation error becomes part of the audit trail.
For Roth IRAs and other accounts not subject to lifetime RMDs, this specific consequence does not apply, but the Form 5498 inaccuracy remains.
3. In-kind distribution events at incorrect value
If you take an in-kind distribution of an asset without a current FMV, the distribution value reported on Form 1099-R may be based on a stale or placeholder figure. The Form 1099-R goes to the IRS and to you for tax-return purposes. An incorrect distribution value can produce an inaccurate tax bill — too low (and potentially under-reporting income) or too high (and overpaying tax).
4. Audit-trail risk
If your account is ever examined by the IRS, an FMV gap is a flag. The examination will look for:
Why a current value wasn't submitted.
Whether the asset was actually worth what was eventually reported.
Whether other reporting obligations were similarly missed.
A single late submission with documentation showing why is typically a manageable issue. A pattern of missed FMVs, gaps in supporting records, and inconsistent valuations is harder to defend.
5. Potential late-submission fees
Retired.com may apply a late-submission or rush-processing fee for FMV submissions received after the published deadline. Specific fee terms are in the published fee schedule.
How to remedy a missed deadline
If you've missed the deadline, the right move is to submit as soon as possible — even after the deadline. The sooner the correct FMV is on file, the easier the corrections.
Submit the current-year FMV with supporting documentation through the standard submission process. Note in the submission that it is being made post-deadline.
Contact the Service Team to coordinate any necessary correction. If Form 5498 has already been filed, a corrected Form 5498 may need to be issued.
Recalculate any affected RMD if the current-year RMD depended on the prior-year FMV. If the corrected FMV produces a different RMD, file IRS Form 5329 with the corrected calculation and pay any additional excise tax owed (reduced if within the two-year correction window under SECURE 2.0).
Update your own records to reflect both the corrected FMV and the timing of the correction.
We recommend consulting a tax advisor or attorney for guidance specific to your situation, particularly if a missed FMV has affected an RMD or distribution calculation.
Multiple missed years
If FMV submissions have been missed for multiple years, the remediation is more involved:
Each year's FMV needs to be reconstructed from contemporaneous documentation — what the asset was worth as of each missed December 31, not what it is worth today.
For real estate or other assets where this reconstruction is difficult, engaging a qualified valuation professional may be necessary.
RMD calculations may need to be reworked across multiple years, with corresponding Form 5329 amendments and excise-tax recalculations.
This is the scenario where the custodian's, tax advisor's, and (potentially) outside-counsel's roles all matter most. Don't try to reconstruct multiple years of FMVs without professional support if material amounts are involved.
Best practices to avoid late submissions
A few simple practices prevent most missed deadlines:
Calendar the deadline annually as soon as it is announced. Add a reminder 30 days before.
Engage your appraisers and sponsors early. Year-end NAV statements from sponsors and BPOs from real estate professionals often have their own lead times. Requesting in January for a Q1 deadline rarely leaves enough room.
Don't wait for the last asset. If you have five non-publicly-traded assets and you have valuations for four, submit those four and follow up on the fifth separately rather than waiting to submit everything at once.
Keep your contact information current in the account portal so deadline notifications reach you reliably.
Common questions
Is there a grace period after the deadline?
Retired.com may accept late submissions, but with potential fee implications and a real risk of missing the May 31 IRS deadline if the late submission lands close to it. The internal deadline exists to leave room for processing — submissions after it lose that buffer.
What if my appraiser can't deliver before the deadline?
Contact the Service Team. In some cases, a placeholder submission based on a documented preliminary estimate can be filed and updated when the formal appraisal lands. The substitution requires a corrected Form 5498. We recommend consulting a tax advisor on whether this approach fits your situation.
Will Retired.com remind me?
Yes, multiple times — through the account portal, through your registered email address, and through direct outreach from the Service Team for accounts with assets requiring submission. That said, the responsibility for timely submission sits with the account holder, not with Retired.com's reminders.
Does a missed FMV expose me to IRS audit?
A single missed or late FMV is not, by itself, an audit trigger. But it creates a flag in the IRS's records — a Form 5498 with no value or a value flagged as not current. Repeated or systemic FMV gaps elevate audit risk. The cleanest defense is current, methodology-based, documented submissions every year.
Need more support? Contact our Service team
Select "Start a Conversation" from the Chat menu or call us at 1-800-RETIRED