
Alternative Assets (29)—DOL Proposal and the Six Defined Factors: The Valuation Factor (2)
Key Points: Can fiduciaries trust the daily valuations of the mutual funds in a plan’s core lineup for participant direction? Yes, but. Fiduciaries are only given valuation “relief” if they review mutual fund documents and, on that basis, determine that the valuations are based on trades in public exchanges. The DOL’s proposed regulation on selecting investments, including alternative assets, 2026-06178.pdf, identifies six factors that should be considered in the process of selecting any investments for participant-directed plans, such as 401(k) plans and private sector 403(b) plans. The six factors are: Performance, Fees, Liquidity, Valuation, Performance Benchmark, and Complexity. The proposal describes each of those factors and provides 20 examples of their application. In earlier posts, I covered five of the factors—Performance, Fees, Performance Benchmarks, Complexity, and Liquidity, and their examples. My last post, Alternative Assets (28), described the Valuation factor which, like the Liquidity factor is particularly important for the evaluation of private funds and other non-publicly traded assets. This article discusses the first example under the Valuation factor: Valuation; Public exchanges— (i) Facts. A participant-directed individual account plan offers a designated investment alternative that allows participants to acquire shares of a mutual fund registered as an open-end management investment


