Art of the Qualified Plan Audit

Is your auditor a Jack of all trades, but a master of none?

Posted By: Maria T Hurd, CPA, RPA Improved EPCRS : More Self-Correction Options Inside the Box Perfection is aspirational, especially when it comes to retirement plan administration. That is why 30 years ago, in 1991, the IRS created the EPCRS (Employee Plan Compliance Resolution System), a mechanism for plan sponsors to fix mistakes. Compliance with … Continued

Posted By: Maria Hurd, CPA, RPA What Do You Check to Indicate Your Client’s Auditor Performed a Limited Scope Audit On Your Mark, Get Set, GO!, Or Don’t Go….It’s Up to You! The AICPA postponed the mandatory effective date of the new audit standard, SAS 136, until next year, but the DOL had already updated … Continued

In Summary Auditor Selection Responsibility: Plan sponsors must evaluate the qualifications of the CPA firm hired for a retirement plan audit, a challenging task given the complexity of the work. The Department of Labor (DOL) and AICPA provide resources to assist in this selection, emphasizing that the size of an audit practice and its commitment … Continued

  Maria Hurd, CPA, RPA, Christopher Ciminera, CPA, QKA,  and many members of our employee benefit plan audit team are highly sought after for speaking events. Here are a few upcoming speaking events that we thought you might be interested in attending. APRIL 19, 2021: Death, Taxes, and Retirement Plan Operational Failures – On April … Continued

In Summary Certified Value Might Not Be Valid When Limited Scope Certification Is: An ERISA Section 103(a)(3)(C) certification guarantees completeness and accuracy based on a financial institution’s ordinary business records, but this does not assure compliance with GAAP. If the custodian’s “best available information” is not fair value, a certified value is provided that auditors … Continued

Posted By Maria T. Hurd, CPA How Big Can a Retirement Plan Be and Still Qualify for the Small Plan Audit Exemption? “Define Large.” It is a question I often get from advisors hoping to get their clients out of a retirement plan audit. Until now the answer has been simple: 100 participants is the … Continued

In Summary Correction Options Exist Even if Funds Are Gone: Overpayments, which often represent a timing difference, can be corrected through the Employee Plan Compliance Resolution System (EPCRS). When a participant cannot return the money, viable alternatives include amending the 1099-R to remove favorable tax treatment, making a “make-whole” contribution to defined benefit or balance-forward … Continued

In Summary Hardship Distribution Substantiation Options: The plan may require backup documentation for the hardship reason and amount, or allow the participant to self-certify the hardship reason, amount, and financial necessity in writing. Self-certification requires the employer to provide specific written notifications regarding taxability and rules, and the participant must maintain the backup. Preventing Ineligible … Continued

In Summary GAAP and ERISA Require Disclosures for Certain Transactions: Related Party transactions that are material to the financial statements must be disclosed in the notes, providing details like the relationship, transaction description, and dollar amounts (FASB ASC 850). Separately, all transactions with the broader group of Parties-in-Interest must be disclosed unless a statutory or … Continued