Stock Valuation Timing
ESOP shares are not publicly traded, meaning they’re not valued daily like stocks on the open market. Instead, they’re appraised by an independent valuation firm once a year. This valuation is often done as of December 31 and finalized sometime in the first or second quarter of the following year.
When drafting a QDRO, it’s critical to reference the correct valuation date. For example, if the intent is to divide one-half of a participant’s balance as of the date of divorce, but the plan only provides annual valuations, you may need to specify the most recent plan valuation date or the valuation immediately before or after the divorce. Failing to clarify the date can lead to disputes or inequitable results.

