; coordination with title. 497. Terms and rules relating to covered assets (a) Covered asset For purposes of this part, except as otherwise provided in this part, the term covered asset means any asset other than— (1) any interest of the taxpayer in an applicable savings plan or in a defined benefit plan, (2) any cash or cash equivalent, or (3) any private placement life insurance or annuity contract described in section 72(e)(12)(D). (b) Tradable covered asset For purposes of this part, except as provided in section 496(d), the term tradable covered asset means— (1) any covered asset if— (A) interests in such asset are traded on an established securities market, (B) interests in such assets are readily tradable on a secondary market (or the substantial equivalent thereof), (C) interests in such assets are available on an online or electronic platform that regularly matches, or facilitates the matching of, buyers and sellers of such assets, or (D) such asset is an asset for which the Secretary determines there is a reasonable basis to determine the asset’s fair market value annually, and (2) any derivative with respect to an underlying investment which— (A) is an asset described in paragraph (1), or (B) is a nontradable covered asset which is identified in regulations or other guidance provided by the Secretary. (c) Nontradable covered asset For purposes of this part— (1) In general The term nontradable covered asset means any covered asset which is not a tradable covered asset. (2) Certain assets only counted for determining aggregate value of assets (A) In general Any asset excluded from treatment as a covered asset under paragraph (1), (2), or (3) of subsection (a) shall be taken into account as a nontradable covered asset in computing the aggregate applicable value of all tradable and nontradable covered assets held by the taxpayer as of the close of any taxable year for purposes of section 495(a)(3). (B) Private placement life insurance and annuity contracts For purposes of subparagraph (A)— (i) In general