✓ Quick answer
Run this 12-point review once a year to confirm your gold IRA is set up exactly as intended and nothing has quietly changed.
The best time is January, once your year-end statements and Form 5498 arrive. The review covers four categories: IRS paperwork accuracy, custodian fee schedule changes, physical holdings reconciliation, and personal information (beneficiaries, contacts, power of attorney). No financial advisor is required. Each point below tells you what to check, where to find it, and what a red flag looks like. Most account holders complete the full 12-point checklist in under 60 minutes.
Why an Annual Gold IRA Review Is Different from a Regular IRA Review
A gold IRA is not a set-and-forget account. Unlike a conventional IRA that holds securities in digital form at a single custodian, a self-directed gold IRA involves at least three separate parties: a custodian who holds the account legally, a depository that physically stores your metals, and in most cases a dealer who facilitated the original purchase and will handle any future buybacks. Errors or fee changes at any of those three layers can go unnoticed for years unless you specifically look for them.
The IRS requires custodians to send Form 5498 each year showing your December 31 fair market value. That annual document is your signal to sit down and run through the list below. Every item in this checklist is verifiable from documents you should already have on file, or that you can request from your custodian in writing.
The 12-Point Annual Checklist
Verify Your Year-End Fair Market Valuation
What to check: The December 31 fair market value (FMV) of your account as reported by your custodian. This figure appears on Form 5498, Box 5, which custodians must provide no later than May 31 of the following year under IRS rules.
Where to find it: Form 5498 mailed to you, your custodian’s online portal, or your year-end account statement. Cross-reference the stated value against the spot price of gold (or silver, platinum, or palladium as applicable) on December 31 for the total weight of metal you hold. Historical spot prices are publicly available through sources such as the London Bullion Market Association or the CME Group.
What to expect: Custodians may value metals at spot price or at a bid price (the price a dealer would pay to buy, which is slightly below spot). Both methods are acceptable. The FMV drives your RMD calculations and your estate value, so accuracy matters.
Red flag: A reported FMV that differs materially from spot price times your stated holdings, with no written explanation of the pricing methodology from your custodian.Confirm Form 5498 and Any Form 1099-R Match Reality
What to check: Form 5498 must reflect the actual holdings and activity in your account for the year. If you took any distribution, you should also have received Form 1099-R. Confirm the gross distribution amount in Box 1 of Form 1099-R matches what you actually received (or the FMV of metals taken as an in-kind distribution, which is reported at the December 31 FMV at time of distribution).
Where to find it: Form 5498 from your custodian (due by May 31) and Form 1099-R if any distribution occurred (due by January 31). The IRS publishes instructions for both forms at irs.gov. Keep both with your annual tax records for at least seven years.
Division of responsibility: Your custodian prepares and files these forms. Your responsibility is to verify that what they filed matches what actually happened in your account.
Red flag: A Form 1099-R issued in a year when you made no withdrawal, or amounts that do not match your distribution records. Contact your custodian in writing immediately to request a corrected form before the tax filing deadline. For a breakdown of distribution codes, see our companion guide on IRS Form 1099-R Box 7 codes for gold IRA distributions.Review the Custodian Fee Schedule for Changes
What to check: Custodians are generally not required to notify you personally of fee increases, as long as revised fee schedules are posted in your account agreement or on their website. Pull the current fee schedule and compare it line by line against the version from 12 months ago. Common fee types to review: annual administration or maintenance fee, storage fee (flat or percentage of value), wire transfer fees, distribution fees, and any new or renamed charges.
Where to find it: Your custodian’s website fee schedule page, your most recent account statement (often includes a fee disclosure), or your original account agreement. Many custodians post a PDF fee schedule that is updated when rates change.
What typical fees look like: Annual administration fees generally run from $75 to $300 or more. Depository storage fees (passed through by custodians) typically range from $100 to $350 per year for flat-rate structures, or 0.10% to 0.50% of account value for percentage-based structures. Some custodians bundle storage and administration; others itemize them separately.
Red flag: A fee increase not authorized by your original agreement, a new fee category that was not disclosed at account opening, or a storage fee structure that has changed (from flat-rate to percentage, or vice versa) without written notice. For a full approach to comparing fee schedules, see: How to Audit Your Gold IRA Custodian Fees.Reconcile the Depository Holdings Statement Item by Item
What to check: Your depository (not your custodian) physically holds the metals. Once a year, reconcile the depository’s holdings statement against your complete purchase history. Confirm that every bar and every coin you purchased is accounted for by product type, weight, and, where applicable, serial number.
Where to find it: Your custodian should forward a copy of the depository holdings statement at least annually, or upon request. Locate your original purchase confirmations or dealer invoices and compare them line by line against the statement. For gold bars, serial numbers provide the most reliable match.
What to note: Minor rounding differences in stated weights are common and not a concern. Missing line items or a total weight that does not match your purchase records are material discrepancies requiring a written inquiry to both your custodian and the depository.
Red flag: Any product missing from the holdings statement, or serial numbers on bars that differ from your purchase confirmation. Report discrepancies in writing to both your custodian and the depository and keep copies of all responses.Confirm Storage Type Matches What You Are Paying For
What to check: Verify whether your metals are in segregated or commingled storage and whether the fee you are paying corresponds to the storage type you selected. Segregated storage means your specific bars and coins are physically separated from other investors’ holdings, each identified by serial number or account tag. Commingled storage pools all coins or bars of the same type and fineness together; you own a proportional share of the pool rather than specific items.
Where to find it: Your original account agreement or deposit confirmation from the custodian, and the current depository holdings statement. A segregated holdings statement should show individual items with serial numbers for bars. A commingled statement typically shows totals by product category.
Why this matters for IRA compliance: Both storage types are IRS-compliant for self-directed IRAs under IRC Section 408(m)(3), provided the depository is an approved facility. The practical difference is in how your specific metals are identified and what happens in a depository insolvency scenario.
Red flag: Paying a segregated storage premium but receiving a holdings statement with no serial numbers or individual item identifiers. Or the reverse: an agreement that specified segregated storage but a statement showing commingled treatment.Review Your Beneficiary Designations
What to check: Your IRA beneficiary designation is a contractual document on file with your custodian. It overrides your will in all cases. Life changes, including marriage, divorce, death of a named beneficiary, birth of a child or grandchild, or an estrangement from a named beneficiary, can make a designation outdated without your noticing. Review the designation on file once a year and update it if anything in your family or financial situation has changed.
Where to find it: Log into your custodian’s portal and navigate to account settings or beneficiary information. If a paper form is on file rather than a digital record, request a copy and confirm it reflects your current wishes. Your custodian is required to keep this document on file and to honor it.
What to look for: Confirm you have both a primary beneficiary and at least one contingent beneficiary named. An IRA with no living beneficiary named at the account owner’s death passes through probate rather than directly to heirs, adding time and legal costs to the estate settlement.
Red flag: A deceased person listed as primary beneficiary, an ex-spouse still named after a divorce finalized (unless intentional), or no contingent beneficiary designated at all. For guidance on per stirpes versus per capita and how beneficiary structures affect inherited IRA treatment, see: Beneficiary Designations for Gold IRAs.Check Your RMD Status
What to check: If you are approaching or past required minimum distribution (RMD) age, confirm whether you must take a distribution this year and whether any amount already taken satisfies the requirement. Under the SECURE 2.0 Act (signed into law December 2022), the RMD starting age is 73 for individuals born between 1951 and 1959, and 75 for those born in 1960 or later. Traditional gold IRAs are subject to RMDs; Roth IRAs are not subject to RMDs during the original account owner’s lifetime.
Where to find it: Your custodian may calculate and send you an annual RMD notice. Cross-check using IRS Publication 590-B (irs.gov/publications/p590b), which contains the Uniform Lifetime Table used for most account owners. The formula is: prior December 31 account balance divided by the applicable distribution period factor from the table.
Important aggregation note: If you hold multiple traditional IRAs, including other gold IRAs, the RMDs for all of them must be calculated separately, but they may be satisfied by withdrawing from any one or combination of traditional IRAs. This is the aggregation rule. For details on how this applies to gold IRA holders: RMD Aggregation Across Multiple IRAs Including Gold.
Red flag: You are age 73 or older, hold a traditional gold IRA, and have not taken a distribution this calendar year with no plan to do so before December 31. A missed RMD triggers an excise tax of 25% of the shortfall (reduced to 10% if corrected within the SECURE 2.0 correction window, as described in IRS Notice 2023-75).Revisit Your Allocation Percentage
What to check: When you opened your gold IRA, you likely had a target allocation in mind: a percentage of your total retirement savings that you wanted held in precious metals. Market movements in your other accounts (equities, bonds, real estate funds) can drift that percentage in either direction over a year without any action on your part. Verify your actual current allocation against your intended allocation.
Where to find it: Total the year-end balance of your gold IRA alongside all other retirement accounts (401k, other IRAs, pension values where estimable). Divide the gold IRA balance by the total to get your current allocation percentage.
What this review is not: This checklist does not recommend a specific allocation percentage. That decision belongs to you and, ideally, a financial professional who knows your full retirement picture. This point simply ensures you are making a deliberate, informed choice rather than letting allocation drift unexamined.
Red flag: Your gold IRA allocation has drifted more than 10 percentage points from your stated plan without a deliberate decision to change it, or you discover you have no stated plan at all.Confirm Contact and Power of Attorney Information Is Current
What to check: Your custodian holds your mailing address, phone number, email address, and in some cases a power of attorney (POA) designation on file. If you have moved, changed phone numbers, updated your email, or changed your POA arrangement, the custodian may still have outdated information. Outdated contact information means you could miss RMD reminders, fee change notices, regulatory communications, or legal notices.
Where to find it: Log into your custodian’s online portal and verify every field in your account profile: mailing address, phone, email, and any authorized agent or POA designation. If the custodian holds a paper POA document, request a copy to confirm it still reflects your intentions and has not expired. Many state POA statutes impose durability and execution requirements; a document drafted years ago may need to be refreshed.
Red flag: A previous mailing address on file, a disconnected phone number, or a POA naming someone who is deceased, incapacitated, or no longer the right person to act on your behalf.Check Custodian and Depository Standing
What to check: Gold IRA custodians are typically state-chartered trust companies or federally chartered institutions. Their regulatory standing is a matter of public record. Depositories maintain insurance coverage (typically through carriers such as Lloyd’s of London) and in many cases CME Group or COMEX approval. Both insurance and regulatory status can change from year to year without direct notice to account holders.
Where to find it: For custodians, check the relevant state banking regulator’s online database. The Conference of State Bank Supervisors (CSBS) maintains links to all state banking department websites at csbs.org. For depositories, request a current certificate of insurance or look for posted insurance documentation on their website. The BBB complaint database at bbb.org and the CFTC’s enforcement database at cftc.gov are also worth checking for any new actions. For a detailed look at how depository insurance works: Insurance Coverage at Gold IRA Depositories.
Red flag: A custodian whose state trust charter status is not current in the regulator’s database, a depository that cannot produce a current certificate of insurance upon request, or a material increase in BBB complaints since your last review.Review Any Pending Buyback or Transaction Paperwork
What to check: If you initiated a buyback, a transfer, or a rollover that was not fully settled before year-end, confirm its current status. Partially completed transactions carry real risk: an indirect IRA rollover (where funds are distributed to you before being deposited into the new account) must be completed within 60 days of the distribution date or the undistributed amount is treated as taxable income and, if you are under 59½, subject to a 10% early withdrawal penalty under IRC Section 72(t).
Where to find it: Your custodian’s transaction history page or a pending orders dashboard. For any rollover initiated late in the prior year, locate the distribution check date and confirm the corresponding deposit completed before the 60-day deadline. A direct trustee-to-trustee transfer, by contrast, does not involve a distribution to you and is not subject to the 60-day clock.
Red flag: A rollover check dated more than 45 days ago with no deposit confirmation, an unsigned or incomplete buyback form, or a transaction that shows pending status in your custodian’s system without an expected completion date.Archive This Year’s Statements and Documents
What to check: Confirm that your archive (physical or digital) includes all of the following for the year just ended: Form 5498, any Form 1099-R, the full year-end custodian account statement, the depository holdings statement, the current custodian fee schedule, all purchase and sale confirmations for the year, and any written correspondence with your custodian or depository.
Where to find it: Documents arrive by mail or are available for download in your custodian’s portal. Download and label them by tax year in a dedicated folder. The IRS generally has three years from your return filing date to initiate an audit (extended to six years if income is understated by more than 25%), so keep IRA-related documents for a minimum of seven years.
Why Form 5498 in particular: Form 5498 is the only document that establishes the official year-end FMV of your account, which drives RMD calculations and estate valuations. It is also the record that proves any nondeductible contributions were made and any rollovers were properly handled. A missing Form 5498 for any prior year should be requested from your custodian immediately.
Red flag: A gap in your records, specifically a missing Form 5498 or a year with no custodian statement at all. Custodians are required to retain these records, so a replacement copy is available upon request.How Long Does This Review Actually Take?
If your documents are organized and your custodian has a functional online portal, 12 points typically take 45 to 60 minutes. The most time-consuming steps are Point 4 (reconciling the depository holdings statement line by line against purchase records) and Point 6 (locating the beneficiary designation currently on file). If you are running this checklist for the first time and need to gather documents from scratch, set aside two hours.
The practical sequence most account holders follow: gather all year-end documents first (Form 5498, custodian statement, depository statement, fee schedule), then run through Points 1 through 12 in order, noting anything that needs a follow-up request to your custodian. Submit all written requests the same day the review is complete, while the details are fresh.
What Your Custodian Must Send You vs What Only You Can Verify
The division of responsibility matters when something turns out to be wrong. These are items your custodian is required to provide or has a regulatory obligation to maintain:
- Form 5498 by May 31 of the following year (IRS requirement)
- Form 1099-R by January 31 following any distribution year (IRS requirement)
- An annual account statement showing activity and year-end balance
- Access to the current fee schedule (generally available on the custodian’s website)
These are items that only you can verify, because they depend on your personal records, original intentions, or circumstances the custodian cannot know:
- Whether the FMV is consistent with the actual spot price on December 31 for your specific holdings
- Whether the depository holdings match your original purchase confirmations by line item
- Whether your beneficiary designation still reflects your current wishes after any life changes
- Whether your overall allocation percentage is where you intend it to be
- Whether the contact information and POA documents on file are still accurate
Your custodian is responsible for administrative accuracy. You are responsible for personal accuracy and for noticing when administrative records do not match reality. The annual review is the point where both responsibilities meet.
Frequently Asked Questions
How often should I review my gold IRA?
Once a year is the minimum. The practical trigger is receiving Form 5498, which custodians must send by May 31. You should also do a quick check any time a major life event occurs: marriage, divorce, death of a beneficiary, a significant change in your overall retirement plan, or a move in the gold price that meaningfully shifts your allocation.
What if Form 5498 shows a value that seems wrong?
Contact your custodian in writing and ask for the specific pricing methodology used to arrive at the December 31 fair market value. Custodians may use spot price, bid price, or a composite price from a recognized market source. All three are acceptable under IRS guidance. If the methodology is sound but the arithmetic is incorrect, request a corrected Form 5498; custodians can file a corrected version with the IRS.
Do I need a financial advisor to do this annual gold IRA review?
No. All 12 points involve reading documents you already have access to and comparing figures. None require a licensed professional. However, if you discover issues during the review, particularly regarding RMD calculations, beneficiary designations in complex family situations, or questions about your overall allocation strategy, consulting a fee-only financial planner familiar with self-directed IRAs is a reasonable next step.
What is the practical difference between segregated and commingled storage for my annual review?
With segregated storage, your specific bars and coins are physically separated from other investors’ holdings and are tracked by serial number. With commingled storage, your gold is pooled with other investors’ holdings of the same product type and fineness. Both structures are IRS-compliant under IRC Section 408(m)(3). For the annual review, the difference shows up in your holdings statement: a segregated statement should list individual items with serial numbers, while a commingled statement shows quantities by product. If you pay for segregated storage and your statement looks like a commingled one, that is a discrepancy to raise with your custodian.
What should I do if my custodian raised fees without advance notice?
First, review your account agreement for a clause that permits fee changes with or without notice. Many custodian agreements include such a clause. If the increase falls within the terms of your agreement, you generally have no contractual claim. If it appears to violate the agreement, submit a written complaint to the custodian and request a response within a specified time. If the issue remains unresolved, you can transfer your IRA to a different custodian via a direct trustee-to-trustee transfer, which is not a taxable event.
How do I verify that my gold IRA custodian is properly regulated?
Gold IRA custodians must be a bank, a federally insured credit union, or a trust company that qualifies under IRS Treasury Regulation 1.408-2(e). State-chartered trust companies are licensed and supervised by their state’s banking department. You can verify a state trust company’s current license status through the state banking regulator’s public database. The Conference of State Bank Supervisors at csbs.org links to every state regulator. If a company offering custodian services cannot demonstrate a current trust charter or banking license, treat that as a serious concern.
Sources
- IRS, Publication 590-A: Contributions to Individual Retirement Arrangements (IRAs), irs.gov/publications/p590a
- IRS, Publication 590-B: Distributions from Individual Retirement Arrangements (IRAs), irs.gov/publications/p590b
- IRS, Instructions for Forms 1099-R and 5498, irs.gov/pub/irs-pdf/i1099r.pdf
- IRS, Retirement Topics: Required Minimum Distributions (RMDs), irs.gov
- IRS Notice 2023-75, SECURE 2.0 Act Guidance on Excise Tax Correction for Missed RMDs, irs.gov
- U.S. Treasury Regulation §1.408-2(e), Custodian qualification requirements for individual retirement accounts
- Internal Revenue Code §408(m)(3), Precious metals eligible for IRA investment
- FINRA, Investor Alert: Self-Directed IRAs and the Risk of Fraud, finra.org
- U.S. Securities and Exchange Commission, Investor Bulletin: Self-Directed IRAs, sec.gov
- IRS Revenue Procedure 2016-47 (as modified by 2020-46), Self-certification for missed 60-day rollover deadline
- Conference of State Bank Supervisors, State banking regulator directory, csbs.org