July 28, 2021
AICPA Employee Benefit Plans update
The AICPA Auditing Standards Board issued a Statement on Auditing Standards No. 136 which will affect plan years ending December 31, 2021 and thereafter.
SAS 136 still allows for a “limited-scope audit,” but making this election is no longer considered a scope limitation. The name of this type of audit has changed under SAS 136. Instead of a “limited-scope audit,” the audit will now be referred to as an “ERISA Section 103(a)(3)(C)” audit.
Here’s what to expect:
-Significant changes to the form and content of the auditor’s report.
-New reporting requirements
-Additional communication requirement from the auditors to those charged with oversight regarding potential audit findings
-Plan sponsors will have the additional responsibilities to:
Assess whether the entity issuing the certification is a qualified institution when electing an ERISA section 103(a)(3)(C) audit.
Ensure the certification meets ERISA requirements and gain an understanding as to which investments and disclosures are certified.
Acknowledge, in writing, that all the conditions are met and that an ERISA section 103(a)(3)(C) audit is permissible.