An ESOP is invested in employer securities which although traded on the OTCBB are not considered "readily tradable on an established securites market". The stock is currently valued by an independent appraiser as of 1/1 and this value has been used for the purchase price on the put obligation (distribution dates are not tied to the valuation date) and all other transaction pursuant to IRC 401(a)(28). Apparently, there is an accounting issue in using the 1/1 appraised value because of the OTCBB trading activity. Has anyone encountered this issue before? Will an appraiser approve a valuation bring-down based on a formula incorporating trading activity?

Hi bfsw ---

I'm sure that you can find an appraiser who will do that.

bfsw or RLL

Do you know precisely what the accounting issue is?