Art of the Qualified Plan Audit

In Summary Differences in Distribution Reporting: There are inconsistencies between GAAP and Form 5500 instructions, particularly concerning benefit distributions. Form 5500, Schedule H includes benefits payable (approved but unpaid claims) as a liability, while accrual basis GAAP financial statements generally report distributions when paid, aligning with Forms 1099-R. Treatment of Corrective Distributions Varies: Accounting for … Continued

In Summary Audit Threshold Change: There was a 2023 change to the Form 5500 participant count rule, which now excludes eligible participants who do not have an account balance on the first day of the plan year from the audit-triggering count. Timing Discrepancies: Various scenarios—including plan mergers, trade date vs. settlement date differences, and spinoffs—create … Continued

In Summary The Honor System in Small Retirement Plans: Due to changes in participant counting rules, many small plans are exempt from mandatory annual financial statement audits, relying instead on a “trust, but verify” honor system. This places a significant responsibility on plan sponsors for oversight. Verification Through Self-Audits or Agreed-Upon Procedures: Plan sponsors are … Continued

In Summary Plan Qualification and Tax Treatment: Retirement plans established in Puerto Rico (PR) receive favorable U.S. tax treatment under ERISA Section 1022(i). Plans covering only PR residents (1022(i)(1)) are exempt from U.S. taxation on trust income, while plans electing full U.S. compliance (1022(i)(2)) can cover both U.S. and PR employees. Key Regulatory Differences Must Be … Continued

On January 31, 2024, Hacienda, (the Puerto Rico Department of the Treasury) issued Internal Revenue Circular Letter No. 24-01 (CL IR 24-01) announcing the 2024 limits for Puerto Rico-qualified retirement plans according to Section 1081.01(h) of the Puerto Rico Internal Revenue Code of 2011, as amended. Following are the applicable 2024 limits for qualified defined … Continued

Waiting for the other shoe to drop is an idiom that means to wait for an expected and inevitable event to occur, usually a negative one. The idiom comes from the idea of a person being disturbed by a neighbor who dropped one shoe on the floor and is waiting for the second shoe to … Continued

In Summary PEP Structure Under the SECURE Act: Pooled Employer Plans (PEPs) are a new type of “open” multiple-employer plan (MEP) created by the SECURE Act, which eliminates the “common interest” rule previously required for closed MEPs. A PEP must designate a Pooled Plan Provider (PPP) as the named fiduciary and plan administrator, offering employers … Continued

In our previous blog post, Pooled Employer Plans (PEPs): The Basics, we outlined the basics of a PEP and will not dig into the details of the financial reporting requirements for these plans. The administrator of a PEP must file an annual Form 5500, Annual Returns/Reports of Employee Benefit Plan, to which the PEP administrator … Continued

The IRS has announced cost-of-living adjustments that should be noted for retirement planning purposes. Below is a chart that outlines employee benefit plan limits for 2024: Plan Limits RETIREMENT & SOCIAL SECURITY 2024 Limit 2023 Limit 2022 Limit Section 401(k), 403(b), 457(b) Elective Deferrals $23,000 $22,500 $20,500 401(k) or 403(b) Catch-Up Contributions $7,500 $7,500 $6,500 … Continued

In Summary PEP Definition and Structure: Pooled Employer Plans (PEPs), established by the SECURE Act, allow unrelated employers to join a single defined contribution plan, which is maintained by a pooled plan provider (PPP). This “open MEP” structure treats the plan as a single entity for both ERISA and IRC compliance, eliminating common-interest requirements that … Continued