Typically, when you are about to begin issuing stock options, you'll need a FMV (Fair Market Value) for those options. Without the 409a, your FMV would be under the scrutiny of the IRS and any tax implications are put on the stakeholders. To stay compliant under IRS Safe Harbor, you need to complete a 409a valuation yearly. I’ve also seen it done for investors, but it is good to check with your legal team on the timing.