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Audits of 403(b) Plans: A Challenging New Audit Area

Author/Moderator: Rebecca J. Miller, CPA
Publisher: AICPA
Availability: 05/01/2010
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Description

Due to regulatory issues, the release of this course has been delayed to May 1, 2010. Please see below for details:

The publication of  Audits of 403(b) Plans: A Challenging New Audit Area is deferred pending guidance on the nature of the audit report or opinion to be offered.

On July 21, 2009, the Department of Labor provided what they intended to be the much anticipated relief for audits of 403(b) plans. See Field Assistance Bulletin 2009-2 at http://www.dol.gov/ebsa/regs/fab2009-2.html.  That relief allows certain contracts to be excluded from the scope of the plan’s financial statements without triggering a rejection of the Form 5500 filing. However, the relief granted by the DOL varies from the relief granted by the IRS in Revenue Procedure 2007-71 (part 8), see http://www.irs.gov/pub/irs-drop/rp-07-71.pdf.  Further, the relief does not extend to other scope considerations the auditor is likely to encounter for plans that have not been subject to audits for decades,; nor required to retain plan based books and records until recently. 

The consequence of all this is the difficulty of defining the scope of the contracts subject to audit – both which contracts may be excluded and who is responsible for making that determination.  Without that basic foundation for the audit, the planning of the engagement, the assessment of the applicable internal controls and the determination of the nature of the auditor’s report or opinion, if any, cannot be provided with any assurance at this time.

The DOL and AICPA are actively working to address these significant issues with hope that guidance will be issued in the near future.  In the interim, the delivery date for the course has been rescheduled to the Spring of 2010.

The audit of the 403(b) plan will be a new growth area for the benefit plan auditor. Learn the similarities and the differences between the audit of a 403(b) plan in comparison to that more familiar vehicle — the 401(k) plan. This course is designed to build upon what you already know about auditing benefit plans. It will provide a background on the tax rules applicable to a 403(b) plan, enabling the auditor to develop a better understanding of how these plans are different and how the audit procedures must be modified. Particular attention will be paid to the open issues created by the first time audit of a benefit plan that may have been in existence for nearly 50 years and whose investments have been managed more like individual retirement accounts, than qualified plan trust accounts.

Objectives:
  • Distinguish between the operating differences of a 401(k) and a 403(b) plan
  • Identify the key issues that must be addressed in preparing for the initial audit of the 403(b) plan
  • Recognize the unique internal controls that should be present for a 403(b) plan
  • Recognize the challenging open issues on the definition of a plan participant and a plan asset
  • Design audit procedures responsive to the unique attributes of 403(b) plans
  • Plan the scope of the audit with particular attention to first time through procedures
  • Apply the accounting requirement for employee benefit plans to this arrangement

Prerequisite:  Familiarity and understanding of the audit process of an employee benefit plan, the basics of ERISA, etc. A working knowledge of the audit requirements of a 401(k) plan will be particularly helpful.

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Excerpts

Videocourse Details

NASBA Field of Study: Accounting and Auditing
Level: Intermediate
Recommended CPE Credit: 8 (Preliminary)
Text
Product# 745760
Availability: 05/01/2010
Regular:$186.25
AICPA Member:$149.00
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