The IRS's recently published 2026 Form 5498 instructions require IRA trustees and custodians to report the year-end fair market value of assets that are not readily tradable or do not have a readily available market value. That includes private company interests, non-traded debt, real estate, partnership interests, and other hard-to-value holdings. It is a reporting line on a tax form, but it points to something larger about how alternative assets have to be administered once they sit inside a retirement account.
The requirement highlights an operational distinction that becomes more important as private assets enter retirement structures. Establishing ownership and establishing value are separate processes. For a publicly traded security, both can usually be derived from the same standardized market data: the position is known, and the market price is available on demand. Private assets break that convenience apart. There is no daily quote to reference, no exchange feed to reconcile against, and no automatic way to keep a valuation current.
That is why private assets require a different operating model. The custodian has to maintain an accurate ownership record while separately obtaining appropriate valuation information and associating it with the correct asset and account. Ownership changes, capital calls, distributions, and updated valuations all have to remain consistent with the record ultimately used for participant reporting. When those elements drift apart, the problem does not show up immediately. It shows up at reporting time, when the fair market value on the form has to be defensible.
Alternative-asset custody is therefore partly a data-governance problem. The asset record, the ownership record, the valuation process, and the reporting record cannot operate as independent silos simply because the asset lacks a daily market price. In practice, supporting these assets well means maintaining:
- Account-level ownership records that identify precisely what is held and on whose behalf
- A valuation process that captures and associates appropriate values with each asset
- Reconciliation that keeps capital activity, distributions, and ownership changes aligned
- A recordkeeping trail that can substantiate the reported value when it is examined
The IRS requires the resulting fair market value to appear in the account's annual reporting. The infrastructure underneath has to preserve the information that makes that value credible, throughout the year rather than only at year-end.
This is where Austin Capital Trust Company's regulated trust infrastructure fits. ACTC supports alternative assets through account-level ownership records, segregation, reconciliation, and the recordkeeping required to support valuation and reporting. The point is not simply to hold the asset. It is to preserve a record complete enough that ownership and value can both be substantiated when required.
Private markets may not produce a continuous market price. The institutions holding them still need a continuous and defensible record of ownership. As retirement portfolios continue to move into alternatives, that record, not the presence of the asset alone, is what will keep the reporting sound.
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