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Employer-stock valuation checklist

Create a readiness file for ROBS employer-stock valuation work: scope, independence, company records, financial support, methods documentation, conflicts, fiduciary review, and handoff evidence. The tool does not value stock or decide compliance.

Annual administration checklistProvider due-diligence checklistAnnual administration guide

Direct answer

Use this checklist to organize the evidence a plan fiduciary, TPA, auditor, appraiser, CPA, or ERISA counsel may need before relying on an employer-stock valuation. It is not a legal opinion; do not use it as legal advice, tax advice, investment advice, fiduciary clearance, appraiser recommendation, or fair-market-value estimate.

Build the employer-stock valuation readiness file

Select documented facts only. Do not enter revenue, profit, purchase price, payroll, tax, EIN, participant, customer, or private business figures.

Valuation context
Facts that change follow-up

Checklist reflects the displayed inputs.

Checklist summary

Completed / applicable
0/15
N/A
0
In progress
0
Missing evidence
0
Follow-up
11

Counts exclude N/A tasks from the denominator. There is no stock value, range, compliance rating or binary clearance result.

Engagement independence and scope

Define the valuation purpose, users, standard of value, premise, and report scope

Professional practiceFollow-up fact needed
Stable ID:
valuation-01
Owner:
Plan fiduciary with valuation specialist
Basis classification:
Professional practice
Source:
Professional practice standard for AICPA members performing valuation engagements; not federal law.
Required evidence:
Engagement letter or scope memo naming purpose, valuation date, intended users, standard of value, premise, limitations, report type, and deliverables.
Warning:
A generic price estimate is not the same as a scoped valuation engagement for plan employer stock.
Next action:
Ask the specialist to identify exactly what conclusion, calculation, or limited-scope product is being provided.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Document independence, compensation, prior relationships, and reliance limits

Federal authorityFollow-up fact needed
Stable ID:
valuation-02
Owner:
Plan fiduciary
Basis classification:
Federal authority
Source:
DOL describes fiduciary loyalty, prudence, conflict avoidance, and service-provider monitoring.
Required evidence:
Conflict questionnaire, fee arrangement, referral/payment disclosures, prior-work relationship notes, reliance limits, and fiduciary review notes.
Warning:
Provider-directed or promoter-influenced valuation can create conflict questions; the tool cannot clear them.
Next action:
Escalate unresolved independence or compensation conflicts to ERISA counsel before relying on the report.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Valuation date and purpose

Anchor the valuation date to the plan event or reporting use

Prudent workflowFollow-up fact needed
Stable ID:
valuation-03
Owner:
Plan fiduciary with TPA and appraiser
Basis classification:
Prudent workflow
Source:
IRS ROBS checks requested stock valuation and stock purchase information and identified asset valuation as a problem area.
Required evidence:
Valuation date memo tied to annual reporting, formation stock purchase, redemption, distribution, sale, shutdown, financing, or material event.
Warning:
Cadence and scope are not universally fixed; plan terms, transactions, reporting, auditor/TPA requests, and facts determine what is needed.
Next action:
If purpose is unknown, identify the next filing, transaction, or participant-account use before requesting work.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Company, legal, and capitalization records

Assemble corporate formation, governance, cap table, and stock ledger records

Federal authority
Stable ID:
valuation-04
Owner:
Corporate secretary with plan fiduciary
Basis classification:
Federal authority
Source:
IRS ROBS checks requested stock purchase, plan status, participant, and general business information.
Required evidence:
Articles, bylaws, minutes, resolutions, stock certificates/subscriptions, cap table, stock ledger, shareholder agreements, option/warrant notes, and amendments.
Warning:
Missing capitalization records can make a valuation review incomplete even when financial statements exist.
Next action:
Reconcile plan-owned shares to corporate records before handing data to the valuation specialist.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Financial statements, tax returns, and normalization

Collect financial statements, tax returns, accounting policies, and normalization support

Professional practiceFollow-up fact needed
Stable ID:
valuation-05
Owner:
Company management with CPA
Basis classification:
Professional practice
Source:
AICPA SSVS describes professional valuation development and reporting considerations for business interests.
Required evidence:
Balance sheets, income statements, cash-flow statements when available, general ledger extracts, tax returns, accounting policy notes, owner compensation notes, related-party items, add-backs, and normalization support.
Warning:
Do not paste revenue, profit, payroll, customer, or tax figures into this browser tool.
Next action:
Prepare a controlled data room and record only document references here.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Forecasts and assumptions

Document forecasts, budgets, backlog, customer concentration, and assumption ownership

Professional practiceFollow-up fact needed
Stable ID:
valuation-06
Owner:
Company management with valuation specialist
Basis classification:
Professional practice
Source:
Professional valuation work should document assumptions and information considered; this classification is professional practice, not a federal mandate.
Required evidence:
Forecast package, budget approval, assumption owner, backlog or pipeline support, customer/vendor concentration notes, sensitivity questions, and management representation limits.
Warning:
Unsupported optimistic forecasts are evidence gaps, not proof of value.
Next action:
If forecasts are unavailable, ask whether the selected methods can proceed and what limitations must be disclosed.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Industry and market data

Preserve industry, market, economic, and comparable-data sources

Professional practice
Stable ID:
valuation-07
Owner:
Valuation specialist
Basis classification:
Professional practice
Source:
Authoritative professional valuation standards; not federal law.
Required evidence:
Industry reports, market data, economic assumptions, guideline company or transaction data, source dates, screening criteria, and exclusion notes.
Warning:
Market data should be reproducible enough for fiduciary review; unsupported multiples are not enough.
Next action:
Ask the specialist to cite data sources, dates, and filters used.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Stock rights, restrictions, control, and marketability

Review share class rights, restrictions, control level, and marketability facts

Federal authorityFollow-up fact needed
Stable ID:
valuation-08
Owner:
Plan fiduciary with corporate counsel and appraiser
Basis classification:
Federal authority
Source:
ERISA defines adequate consideration and current value using FMV or good-faith fiduciary determination language for relevant contexts.
Required evidence:
Share class terms, voting/dividend/liquidation rights, transfer restrictions, buy-sell provisions, control analysis, marketability analysis, and counsel/appraiser questions.
Warning:
Control and marketability issues can materially affect analysis; this tool does not calculate discounts or value.
Next action:
Ask counsel/appraiser which rights or restrictions matter and how they are documented.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Methods and reconciliation

Confirm valuation methods considered, selected, excluded, and reconciled

Professional practice
Stable ID:
valuation-09
Owner:
Valuation specialist with fiduciary reviewer
Basis classification:
Professional practice
Source:
Professional practice standard for developing and reporting valuation conclusions or calculations.
Required evidence:
Income, market, and asset approach consideration; method selection/exclusion rationale; key assumptions; sensitivity notes; reconciliation narrative; and report limitations.
Warning:
The checklist cannot judge whether methods are correct or whether a conclusion is reasonable.
Next action:
Ask for a plain-English methods memo when fiduciaries cannot follow the report logic.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Employer-stock transactions and allocations

Tie stock purchases, redemptions, allocations, distributions, and participant records to valuation support

Federal authorityFollow-up fact needed
Stable ID:
valuation-10
Owner:
TPA, recordkeeper, plan fiduciary
Basis classification:
Federal authority
Source:
IRS requested stock valuation and stock purchases and noted Form 1099-R and filing issues in ROBS checks.
Required evidence:
Transaction documents, allocation records, participant statements, redemption/distribution packages, Form 1099-R analysis when relevant, and TPA handoff notes.
Warning:
Transaction activity adds valuation and prohibited-transaction questions; silence should stay follow-up.
Next action:
Route stock transaction facts to TPA, appraiser, CPA, and counsel before records close.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Conflicts and prohibited-transaction review

Screen related-party and party-in-interest facts for counsel review

Federal authorityFollow-up fact needed
Stable ID:
valuation-11
Owner:
Plan fiduciary with ERISA counsel
Basis classification:
Federal authority
Source:
ERISA section 406 restricts transactions involving parties in interest and fiduciary self-dealing; exceptions and consequences are fact-specific.
Required evidence:
Related-party list, party-in-interest analysis questions, transaction flow, compensation/referral disclosures, counsel memo or escalation notes, and unresolved facts register.
Warning:
This checklist prompts conflict review; it does not approve transactions, determine exemptions, or provide legal advice.
Next action:
Escalate related-party involvement, owner guarantees, leases, loans, expenses, compensation, or provider conflicts to ERISA counsel.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Appraiser qualifications and reliance limits

Record specialist credentials, standards followed, assumptions, and reliance limits

Professional practiceFollow-up fact needed
Stable ID:
valuation-12
Owner:
Plan fiduciary
Basis classification:
Professional practice
Source:
USPAP is a professional appraisal standard; applicability depends on appraiser discipline, credential, law, engagement, and user requirements.
Required evidence:
CV or credential record, standards named, certification/representation, information relied upon, management representations, limiting conditions, independence statement, and engagement exclusions.
Warning:
Do not describe professional standards as federal law or as automatic legal compliance.
Next action:
Ask whether AICPA SSVS, ASA standards, USPAP, or another standard applies to the engagement and why.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Report completeness

Check that the report package contains enough support for fiduciary review and handoff

Prudent workflowFollow-up fact needed
Stable ID:
valuation-13
Owner:
Plan fiduciary and TPA
Basis classification:
Prudent workflow
Source:
DOL materials support prudent service-provider selection and monitoring; report-completeness review is workflow, not valuation advice.
Required evidence:
Final report, draft review notes, data request list, management representations, unresolved assumptions, source appendix, TPA/auditor acceptance questions, and version control.
Warning:
A short conclusion page may be insufficient for fiduciary review depending on purpose and facts.
Next action:
Ask TPA, auditor, or counsel what support they need before accepting the final package.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Fiduciary review and decision record

Record fiduciary review questions, decisions, dissent, and reliance boundaries

Federal authority
Stable ID:
valuation-14
Owner:
Named fiduciary or trustee
Basis classification:
Federal authority
Source:
ERISA section 404 frames fiduciary duties of loyalty, prudence, diversification, and plan-document compliance.
Required evidence:
Meeting minutes, questions asked, report review notes, reliance decision, conflict handling, unresolved issues, and professional referrals.
Warning:
Provider or appraiser work does not eliminate fiduciary responsibility to review prudently.
Next action:
Document what was reviewed, what was not decided, and which professionals own open questions.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

Retention and handoff

Create a valuation file index and handoff package

Prudent workflowFollow-up fact needed
Stable ID:
valuation-15
Owner:
Plan administrator with corporate records owner
Basis classification:
Prudent workflow
Source:
IRS ROBS checks requested records on valuation, stock purchases, rollover information, participants, filings, and business information.
Required evidence:
Indexed valuation folder, source-data inventory, report versions, TPA/auditor/CPA/counsel handoff log, retention owner, and next-review trigger list.
Warning:
Keep private business figures in controlled records, not in this browser-local checklist.
Next action:
Copy only task status and document-location references into the permanent file.

Use document locations or reference names, not private figures.

Required when you manually mark an applicable task N/A.

How to use the checklist

Start with the checklist facts, then keep each status tied to a record a fiduciary or reviewer can find later.

  1. Select only documented facts. Unknown purpose, transaction, conflict, rights, forecast, specialist, and reporting-stage facts become follow-up prompts.
  2. For each task, choose not-started, in-progress, complete, or N/A. Completed tasks require an evidence/reference note. Manual N/A requires a reason.
  3. Use document locations, binder names, and questions. Do not enter private business figures, participant data, tax IDs, customer names, payroll details, or stock values.
  4. Copy the final task list into sponsor-controlled records if needed. Refreshing or leaving the page can clear the session.

Example workflow

A year-end reporting review might start by confirming the valuation date and intended use, then collecting corporate records, current financial statements, prior valuation support, and TPA reporting needs. If the plan also has a redemption, distribution, sale, financing, or other employer-stock transaction, the transaction task stays applicable and adds conflict, allocation, and counsel handoff questions.[1]

A formation purchase or new-stock transaction should not rely only on a promoter or provider label. The file should identify who scoped the work, who paid the specialist, what standards were followed, which information was supplied, what limitations exist, and how fiduciaries reviewed the result.[1][2]

Limitations and red flags

The checklist separates document readiness from valuation judgment so gaps are escalated instead of treated as clearance.

  • No valuation output: no FMV, range, discount, multiple, rating or binary compliance conclusion.
  • No false annual-appraisal mandate: cadence and scope depend on plan documents, transactions, reporting, fiduciary duties, auditor/TPA needs, and facts.
  • Red flags include promoter-directed valuation, undisclosed referral compensation, missing cap table records, unsupported forecasts, unexplained discounts, related-party transactions, stale prior reports, and reports that do not state reliance limits.
  • DOL proposed adequate-consideration rules, if consulted elsewhere, must be treated as proposed unless finalized. This page relies on current statutory and agency materials and does not present proposed rules as binding.

Questions for the appraiser, TPA, CPA, and counsel

Use these questions to assign each valuation issue to the professional responsible for scope, reporting, tax, plan administration, or legal review.

  • What valuation date, purpose, intended users, standard of value, premise, and report type are being used?
  • Which professional standards apply: AICPA SSVS, ASA standards, USPAP, another credential requirement, or engagement-specific rules?
  • What independence, compensation, referral, prior-service, and reliance-limit disclosures should fiduciaries review?
  • How are control, marketability, restrictions, voting rights, buy-sell provisions, and share classes addressed?
  • Which records does the TPA or auditor need for Form 5500, participant statements, allocations, redemptions, distributions, or plan termination?
  • Which related-party facts or prohibited-transaction questions require ERISA counsel before reliance?

Checklist universe

The model contains 15 stable tasks across engagement independence/scope, valuation date and purpose, company/legal/capitalization records, financial statements/tax returns/normalization, forecasts/assumptions, industry/market data, stock rights/discounts/control/marketability, methods and reconciliation, employer-stock transactions/allocations, conflicts/prohibited-transaction review, appraiser qualifications/reliance limits, report completeness, fiduciary review/decision record, and retention/handoff.

valuation-01 · professional-practice

Define the valuation purpose, users, standard of value, premise, and report scope

Engagement independence and scope

valuation-02 · federal-authority

Document independence, compensation, prior relationships, and reliance limits

Engagement independence and scope

valuation-03 · prudent-workflow

Anchor the valuation date to the plan event or reporting use

Valuation date and purpose

valuation-04 · federal-authority

Assemble corporate formation, governance, cap table, and stock ledger records

Company, legal, and capitalization records

valuation-05 · professional-practice

Collect financial statements, tax returns, accounting policies, and normalization support

Financial statements, tax returns, and normalization

valuation-06 · professional-practice

Document forecasts, budgets, backlog, customer concentration, and assumption ownership

Forecasts and assumptions

valuation-07 · professional-practice

Preserve industry, market, economic, and comparable-data sources

Industry and market data

valuation-08 · federal-authority

Review share class rights, restrictions, control level, and marketability facts

Stock rights, restrictions, control, and marketability

valuation-09 · professional-practice

Confirm valuation methods considered, selected, excluded, and reconciled

Methods and reconciliation

valuation-10 · federal-authority

Tie stock purchases, redemptions, allocations, distributions, and participant records to valuation support

Employer-stock transactions and allocations

valuation-11 · federal-authority

Screen related-party and party-in-interest facts for counsel review

Conflicts and prohibited-transaction review

valuation-12 · professional-practice

Record specialist credentials, standards followed, assumptions, and reliance limits

Appraiser qualifications and reliance limits

valuation-13 · prudent-workflow

Check that the report package contains enough support for fiduciary review and handoff

Report completeness

valuation-14 · federal-authority

Record fiduciary review questions, decisions, dissent, and reliance boundaries

Fiduciary review and decision record

valuation-15 · prudent-workflow

Create a valuation file index and handoff package

Retention and handoff

Privacy and browser-local operation

The checklist has no lead form, account, cookies, local storage, network submission, URL query output, clipboard access, reminder function, or private-data field. The interface asks for documented applicability facts and evidence references only, not private business figures.

Frequently asked questions

These answers clarify what the checklist can support and where professional valuation or legal judgment remains outside the tool.

Does federal law require every ROBS plan to obtain an independent appraisal every year?

This page does not make that universal claim. Valuation cadence and scope depend on the plan document, current transactions, Form 5500 or participant-account reporting, auditor or TPA needs, fiduciary process, and facts. The checklist keeps annual reporting and transaction events visible without stating a false blanket mandate.

Does the checklist calculate FMV or decide adequate consideration?

No. It organizes inputs, questions, evidence, and follow-up. It does not calculate a value, range, discount, rating or binary result, adequate-consideration conclusion, or fiduciary opinion.

Can a provider-supplied valuation be enough?

Maybe, depending on facts and the fiduciary's review. IRS ROBS materials identify promoter fees and valuation of assets as problem areas, and DOL fiduciary materials emphasize prudence and conflict avoidance. The file should show independence, scope, reliance limits, and fiduciary review rather than relying on a label.

Does the tool store valuation information?

No. The checklist is browser-local for the current page session. It does not use network submission, cookies, local storage, query strings, clipboard access, or accounts. Keep private figures in sponsor-controlled records, not in the tool.

Sources checked August 13, 2026

The source list separates federal authority, agency education, and professional valuation standards so readers can see what each source supports.

  1. [1] IRS Rollovers as Business Start-Ups Compliance Project

    Official IRS page last reviewed November 16, 2025 and checked August 13, 2026. It says ROBS plans are not considered abusive tax-avoidance transactions but are questionable, warns determination letters do not protect incorrect operation, says compliance checks requested stock valuation and stock purchases, and lists promoter fees and valuation of assets among problem areas.

  2. [2] DOL Fiduciary Responsibilities

    Official DOL page checked August 13, 2026. It states fiduciaries must act solely in participants' and beneficiaries' interests, act prudently, diversify to minimize large losses, follow plan documents consistent with ERISA, and avoid conflicts of interest.

  3. [3] ERISA section 3 definitions

    Statutory text checked August 13, 2026. Used for adequate-consideration and current-value concepts, including FMV or good-faith fiduciary determination language in the relevant definitions.

  4. [4] ERISA section 404 fiduciary duties

    Statutory text checked August 13, 2026. Used for fiduciary prudence, loyalty, diversification, and plan-document framing.

  5. [5] ERISA section 406 prohibited transactions

    Statutory text checked August 13, 2026. Used for related-party and fiduciary self-dealing escalation prompts, not for tool-level clearance.

  6. [6] DOL Understanding Retirement Plan Fees and Expenses

    Official DOL publication checked August 13, 2026. Used for service-provider selection and monitoring concepts.

  7. [7] AICPA Statement on Standards for Valuation Services VS Section 100

    AICPA resource checked August 13, 2026. It says AICPA members performing valuation engagements to estimate value are required to follow VS Section 100, subject to exceptions. This is professional practice, not federal law.

  8. [8] ASA Business Valuation Standards

    Professional valuation standards source checked August 13, 2026. Classified as professional practice, not federal law.

  9. [9] The Appraisal Foundation USPAP

    Professional appraisal standards source checked August 13, 2026. Applicability depends on the appraiser, credential, engagement, law, and user requirements; not presented as a universal ROBS legal mandate.

Authorship, disclosure, and date

Written for 401kROBS by Dennis Shirshikov. Published 2026-08-13; last modified 2026-08-13. 401kROBS may earn compensation from some provider relationships, but this tool does not rate providers, recommend appraisers or providers, calculate value, or use compensation as an input.