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.