This document provides an overview and summary of the topics covered in two concurrent sessions on auditing pension plans. The first session discusses the top 10 most common audit findings for pension plans and an overview of Department of Labor initiatives affecting plan audits. The second session focuses on 401(k) plan auditing concerns and issues, including features of 401(k) plans, the audit process, common mistakes, and fraud risks. It also discusses recent Department of Labor initiatives to improve employee benefit plan audit quality such as firm inspections and reviews.
This document provides a summary of trending topics in employee benefit plans. It outlines proposed changes to regulations including new mortality tables and Form 5500 revisions. Common areas of noncompliance include failing to operate plans prudently and for the exclusive benefit of participants. The document also discusses fiduciary responsibilities, common audit deficiencies found by the DOL, current DOL and IRS enforcement issues, fraud risk areas, and resources.
For nearly 40 years, ERISA has required retirement plan fiduciaries to ensure the reasonableness of service and investment fees paid by the plan. However, fee reasonableness has only recently grabbed headline attention due largely to the finalization of the 408(b)(2) regulations and the Missouri district court's decision in Tussey v. ABB, Inc. Despite the strength of its fee reasonableness standard, ERISA provides little practical guidance as to how and when plan fiduciaries should be making and documenting their fee reasonableness determinations. In this presentation, we provide a historical overview of the legislative, regulatory and judicial context surrounding this fundamental fiduciary duty; a look at recent Department of Labor regulatory examination activity centered on fee reasonableness; and a practical, step-by-step guide to meeting the fee reasonableness requirements.
You're going to need a bigger boat
Held at the Heldrich in New Brunswick, New Jersey, this event marked the newest one-day event covering equity compensation and brought together professionals working in the equity compensation field from across North America. Event partners Rutgers' School of Management and Labour Relations, and the school's Executive and Professional Education (EPE) program modeled the event after the Annual CEP Symposium at Santa Clara University.
Featuring comments from Joe Purdy, CEP, Solium Jennifer Namazi, CEP, NASPP, Ben Needham, CEP, MindBody, and John Hammond, CEP, bendystraw
IRS, DOL (and PBGC) Audits and Other MattersHarvey Katz
The document discusses insights from a practitioner on IRS audits of retirement plans. It provides an overview of the audit process, from initial selection and document requests to closing procedures. Key points include tailoring responses based on the perceived audit focus, limiting direct document production to the IRS, and identifying errors upfront to facilitate correction. The goal is to minimize further investigations or financial consequences through a rigorous yet measured response.
What you'll learn:
Reasoning behind this new guide
Major changes since 2005
Reasonable compensation changes
Expanded audit guidance
Cognizant agency rules
The document discusses the role and responsibilities of an audit committee. It provides an overview of how an audit committee should provide oversight of an organization's financial reporting and internal controls. This includes coordinating with leadership, developing an audit committee charter, overseeing external financial reporting and the external audit, monitoring internal controls and risk management, and reporting to the full board of directors. The document also describes services that McCracken Alliance Partners (MAP) can provide to assist audit committees, such as performing reviews, providing temporary audit committee members, and advising audit committees.
ASC 606: Accounting for Contracts with Customers, transforms the way all companies recognize revenue for the sale of goods and services. The implementation of the new standard impacts processes, people and systems for all sectors of the organization from the accounting and finance team to legal and human resources.
Justine Jacob, Senior Manager and Jordan Scheiderer, Director from MorganFranklin Consulting, have spent the last three years assisting public and private companies assess and implement ASC 606 and transform their revenue recognition processes. In this webinar they'll discuss the new standard, share lessons learned from previous implementations and identify the key areas of impact throughout the organization.
The Age of Alignment Part III: Moving From Theory to PracticePearl Meyer
This series is designed to explore a fundamental question that was raised by the NACD Blue Ribbon Commission on Strategy Development: “Does your company’s incentive structure reinforce or unintentionally undermine its chosen strategy?”
Parts 1 and 2 – which are available for replay – outlined a number of diagnostic tools and approaches that boards can use to uncover potential misalignment between their strategy and the compensation program design. We’ve also looked at various protocols that can help improve alignment and drive toward desired goals.
As we know – protocols cannot anticipate every situation. The fresh news on the proposed SEC rules regarding pay for performance disclosure is a perfect example!
I’m joined today by Jim Heim and Theo Sharp, both managing directors in the Boston office of Pearl Meyer and Partners and today we’re going to talk about some real-world examples that show how companies have put these smart theories and protocols into practice and how they’ve remained disciplined toward strategy execution but also flexible to accommodate the unexpected.
This document provides a summary of trending topics in employee benefit plans. It outlines proposed changes to regulations including new mortality tables and Form 5500 revisions. Common areas of noncompliance include failing to operate plans prudently and for the exclusive benefit of participants. The document also discusses fiduciary responsibilities, common audit deficiencies found by the DOL, current DOL and IRS enforcement issues, fraud risk areas, and resources.
For nearly 40 years, ERISA has required retirement plan fiduciaries to ensure the reasonableness of service and investment fees paid by the plan. However, fee reasonableness has only recently grabbed headline attention due largely to the finalization of the 408(b)(2) regulations and the Missouri district court's decision in Tussey v. ABB, Inc. Despite the strength of its fee reasonableness standard, ERISA provides little practical guidance as to how and when plan fiduciaries should be making and documenting their fee reasonableness determinations. In this presentation, we provide a historical overview of the legislative, regulatory and judicial context surrounding this fundamental fiduciary duty; a look at recent Department of Labor regulatory examination activity centered on fee reasonableness; and a practical, step-by-step guide to meeting the fee reasonableness requirements.
You're going to need a bigger boat
Held at the Heldrich in New Brunswick, New Jersey, this event marked the newest one-day event covering equity compensation and brought together professionals working in the equity compensation field from across North America. Event partners Rutgers' School of Management and Labour Relations, and the school's Executive and Professional Education (EPE) program modeled the event after the Annual CEP Symposium at Santa Clara University.
Featuring comments from Joe Purdy, CEP, Solium Jennifer Namazi, CEP, NASPP, Ben Needham, CEP, MindBody, and John Hammond, CEP, bendystraw
IRS, DOL (and PBGC) Audits and Other MattersHarvey Katz
The document discusses insights from a practitioner on IRS audits of retirement plans. It provides an overview of the audit process, from initial selection and document requests to closing procedures. Key points include tailoring responses based on the perceived audit focus, limiting direct document production to the IRS, and identifying errors upfront to facilitate correction. The goal is to minimize further investigations or financial consequences through a rigorous yet measured response.
What you'll learn:
Reasoning behind this new guide
Major changes since 2005
Reasonable compensation changes
Expanded audit guidance
Cognizant agency rules
The document discusses the role and responsibilities of an audit committee. It provides an overview of how an audit committee should provide oversight of an organization's financial reporting and internal controls. This includes coordinating with leadership, developing an audit committee charter, overseeing external financial reporting and the external audit, monitoring internal controls and risk management, and reporting to the full board of directors. The document also describes services that McCracken Alliance Partners (MAP) can provide to assist audit committees, such as performing reviews, providing temporary audit committee members, and advising audit committees.
ASC 606: Accounting for Contracts with Customers, transforms the way all companies recognize revenue for the sale of goods and services. The implementation of the new standard impacts processes, people and systems for all sectors of the organization from the accounting and finance team to legal and human resources.
Justine Jacob, Senior Manager and Jordan Scheiderer, Director from MorganFranklin Consulting, have spent the last three years assisting public and private companies assess and implement ASC 606 and transform their revenue recognition processes. In this webinar they'll discuss the new standard, share lessons learned from previous implementations and identify the key areas of impact throughout the organization.
The Age of Alignment Part III: Moving From Theory to PracticePearl Meyer
This series is designed to explore a fundamental question that was raised by the NACD Blue Ribbon Commission on Strategy Development: “Does your company’s incentive structure reinforce or unintentionally undermine its chosen strategy?”
Parts 1 and 2 – which are available for replay – outlined a number of diagnostic tools and approaches that boards can use to uncover potential misalignment between their strategy and the compensation program design. We’ve also looked at various protocols that can help improve alignment and drive toward desired goals.
As we know – protocols cannot anticipate every situation. The fresh news on the proposed SEC rules regarding pay for performance disclosure is a perfect example!
I’m joined today by Jim Heim and Theo Sharp, both managing directors in the Boston office of Pearl Meyer and Partners and today we’re going to talk about some real-world examples that show how companies have put these smart theories and protocols into practice and how they’ve remained disciplined toward strategy execution but also flexible to accommodate the unexpected.
The document discusses the benefits of exercise for mental health. Regular physical activity can help reduce anxiety and depression and improve mood and cognitive functioning. Exercise causes chemical changes in the brain that may help protect against mental illness and improve symptoms.
The Audit and Compliance Committee Charter outlines the purpose, composition, authority, and specific duties of the Committee. The primary purpose is to oversee Starbucks' accounting, financial reporting, audit processes, and compliance with business conduct policies. The Committee is responsible for appointing and overseeing the independent auditors, reviewing financial reporting and disclosures, monitoring internal controls and compliance, and addressing accounting complaints. It must include at least three financially literate independent directors, meet at least six times per year, and report annually to shareholders.
This document provides guidance on the role of auditing in public sector governance. It discusses key principles of public sector governance including setting direction, instilling ethics, overseeing results, and accountability reporting. The document emphasizes that auditing is important for public sector governance as it provides objective assessments of resource management and achievement of results. An effective public sector audit activity requires independence, a formal mandate, unrestricted access, sufficient funding, competent leadership, objective staff, competent staff, stakeholder support, and adherence to professional standards.
The internal audit charter formally defines the internal audit activity's purpose, authority, and responsibilities. It establishes the internal audit's position within the organization and must be periodically reviewed and approved by senior management and the board of directors. The charter outlines important components like the definition of internal auditing, code of ethics, scope of responsibilities, and reporting structure.
This document provides a practical guide for managing the business risk of fraud. It covers fraud risk governance, fraud risk assessment, fraud prevention, fraud detection, and fraud investigation and corrective action. Appendices provide additional reference materials, sample frameworks and policies, and checklists. The guide is intended to help organizations design and implement effective fraud risk management programs.
BDO General Audit of Financial StatementsBDO Indonesia
BDO Indonesia will conduct an audit of the company's financial statements in accordance with auditing standards. The audit will include evaluating accounting policies, internal controls, risks of misstatement, and assessing accounting estimates. BDO will perform audit procedures to obtain evidence about the financial statements and will express an opinion on whether the statements fairly represent the company's financial position in accordance with standards. BDO will also communicate any significant deficiencies in internal controls identified during the audit.
This document summarizes a webinar about COSO's proposed revisions to its Internal Control - Integrated Framework and the implications for information technology. The webinar featured presentations from Ken Vander Wal of ISACA, David Landsittel of COSO, and Cara Beston of PricewaterhouseCoopers. They discussed COSO's project to update the framework to reflect changes in the business environment and technology. The proposed updates include codifying principles, expanding the financial reporting objective, and increasing the focus on operations and compliance. Technology is now embedded in business and affects all aspects of internal control. The updated framework considers how technology impacts risks and controls across the five components. Attendees were encouraged to review and
Steps for setting up Internal Audit Function / Department in Small / Medium S...Pritesh Hirapara
How to set up internal audit department in India, Strengthen Internal Audit Department, Internal Audit Department for Small and Medium size company in India.
This document provides an overview of internal audit strategy and risk approach for not-for-profit organizations. It discusses the context and challenges not-for-profits face, conceptual frameworks for internal control and governance, a practical internal audit model, resourcing strategies, the internal audit process, and integrating risk management. It proposes a risk-based internal audit approach and roadmap for developing an enterprise risk management framework that embeds risk management into operations. The document is intended to help not-for-profits design and implement an effective internal audit and risk management function.
Fixed Asset Controls and Reporting: Who's Paying Attention to Your Largest As...Duff & Phelps
Often an element of fraud and financial
misstatement, fixed assets get no
respect. Although they’re considered
low risk by auditors, fixed assets need
attention. Are the internal controls really
effective over this perceived low-risk
area? Best practices enhance proper
accounting, valuations and financial
reporting.
An effective compliance program has several key components: conducting a legal risk assessment to identify areas of focus, ensuring the program meets regulatory guidelines, tailoring the program to a company's unique operations, establishing standards and procedures to minimize risks and demonstrate commitment to ethical conduct, and providing training, monitoring, reporting, and investigations to foster a pro-compliance culture. An effective program is process-oriented, integrated into daily operations, and subject to continuous improvement.
There are five main pillars considered critical for building an effective internal audit function in the public sector: perception and ownership, improved processes and governance, legislative support, improved incentives, and commitment to change. Internal auditing has shifted from simply ensuring compliance to adding value by reviewing management procedures and focusing on efficiency and effectiveness, though this requires changes to culture and priorities. Factors like independence, understanding organizational issues, responsiveness, and implementing recommendations impact the internal audit function's effectiveness.
This competency map summarizes Walter Ostrander's coursework in the MBA6014 Financial Accounting course. He has completed all assignments at the distinguished level, demonstrating mastery of accounting theories, practices, and financial statement preparation. The map outlines five competencies, including applying accounting concepts, examining regulatory and ethical issues, integrating accounting across organizations, analyzing financial information, and communicating professionally. For each competency, the document lists multiple assignments addressing topics such as inventory, bonds, internal controls, and cash flow statements.
Auditing Cayman Funds and Crypto FundsDavid Walker
Presentation by Moore Stephens Cayman for the Cayman Islands Institute of Accountants on International Standards on Auditing for Cayman Funds & Cryptocurrency Funds
The document discusses financial management techniques for evaluating energy efficiency investments. It introduces concepts like simple payback period, return on investment, net present value, and internal rate of return. It explains how to calculate each metric and compares their advantages and limitations. The key financial analysis techniques allow comparing energy efficiency project costs and savings over time to different investment alternatives.
The document provides an overview of the requirements for non-profit organizations receiving over $500,000 in federal awards to undergo an A-133 audit. It discusses determining major programs, applicable compliance requirements, internal controls, and procedures auditors will perform to test compliance with each requirement. The presentation also lists reference materials and websites for additional information on A-133 audit requirements and federal grants management.
Accretive Health - Quality Care - Health Care Quality AccretiveHealth
This document discusses Accretive Health's quality and care coordination initiative. It aims to optimize quality and financial results across episodes of care by strengthening relationships between hospitals, physicians, and payors. The initiative utilizes predictive analytics, workflow technology, and population health management infrastructure to continuously improve patient care. This is expected to generate savings that are shared among participating providers, payors, and Accretive Health. Oncology care is highlighted as an area of growing costs and complexity that can benefit from a coordinated, data-driven approach to care.
This document provides a summary of Sanjeev Kumar Jain's qualifications and work experience. It outlines his education which includes a CA, DISA, and M.Com. It then details his employment history working for Vodafone Mobile Services Ltd as a Senior Manager for over 7 years and for Vodafone India Ltd as a Deputy Manager for over 5 years in telecommunications. It highlights his key responsibilities and achievements in financial management and internal auditing.
The document discusses various aspects of budgeting including:
1. It defines budgeting and provides objectives such as assisting management with planning, coordinating, and controlling operations.
2. It discusses four aspects of the control process: developing plans, communicating plans, motivating people, and reporting performance.
3. It covers capital budgeting and long-range planning, evaluating capital investments, and techniques for analyzing capital project feasibility such as payback periods and accounting rate of return.
Dol audits on the rise are you prepared?SSDLaw2014
The document discusses potential Department of Labor audits of employers for compliance with wage and hour laws. It notes that DOL investigations have increased 42% from 2011 to 2012. Employers can be audited based on complaints, random selection, or as a follow up to a prior investigation. Noncompliance can result in civil monetary penalties, back wages owed to employees, fines, and even criminal sanctions for willful violations. The DOL has broad authority to subpoena records and question employees during investigations. The document provides an overview of key areas that are audited - overtime pay, exemptions from overtime, worker classification as employees vs. contractors, and recordkeeping requirements. It offers recommendations for how employers can review their pay practices in these
This document provides an overview of ERISA compliance requirements for employee benefit plans. It discusses filing Form 5500 annually, having proper plan documents like a summary plan description, and being prepared for potential audits from agencies like the Department of Labor. Filing deadlines and penalties for noncompliance are also reviewed. The presentation aims to help employers understand ERISA obligations and ensure their benefit plans would survive an audit.
The document discusses the benefits of exercise for mental health. Regular physical activity can help reduce anxiety and depression and improve mood and cognitive functioning. Exercise causes chemical changes in the brain that may help protect against mental illness and improve symptoms.
The Audit and Compliance Committee Charter outlines the purpose, composition, authority, and specific duties of the Committee. The primary purpose is to oversee Starbucks' accounting, financial reporting, audit processes, and compliance with business conduct policies. The Committee is responsible for appointing and overseeing the independent auditors, reviewing financial reporting and disclosures, monitoring internal controls and compliance, and addressing accounting complaints. It must include at least three financially literate independent directors, meet at least six times per year, and report annually to shareholders.
This document provides guidance on the role of auditing in public sector governance. It discusses key principles of public sector governance including setting direction, instilling ethics, overseeing results, and accountability reporting. The document emphasizes that auditing is important for public sector governance as it provides objective assessments of resource management and achievement of results. An effective public sector audit activity requires independence, a formal mandate, unrestricted access, sufficient funding, competent leadership, objective staff, competent staff, stakeholder support, and adherence to professional standards.
The internal audit charter formally defines the internal audit activity's purpose, authority, and responsibilities. It establishes the internal audit's position within the organization and must be periodically reviewed and approved by senior management and the board of directors. The charter outlines important components like the definition of internal auditing, code of ethics, scope of responsibilities, and reporting structure.
This document provides a practical guide for managing the business risk of fraud. It covers fraud risk governance, fraud risk assessment, fraud prevention, fraud detection, and fraud investigation and corrective action. Appendices provide additional reference materials, sample frameworks and policies, and checklists. The guide is intended to help organizations design and implement effective fraud risk management programs.
BDO General Audit of Financial StatementsBDO Indonesia
BDO Indonesia will conduct an audit of the company's financial statements in accordance with auditing standards. The audit will include evaluating accounting policies, internal controls, risks of misstatement, and assessing accounting estimates. BDO will perform audit procedures to obtain evidence about the financial statements and will express an opinion on whether the statements fairly represent the company's financial position in accordance with standards. BDO will also communicate any significant deficiencies in internal controls identified during the audit.
This document summarizes a webinar about COSO's proposed revisions to its Internal Control - Integrated Framework and the implications for information technology. The webinar featured presentations from Ken Vander Wal of ISACA, David Landsittel of COSO, and Cara Beston of PricewaterhouseCoopers. They discussed COSO's project to update the framework to reflect changes in the business environment and technology. The proposed updates include codifying principles, expanding the financial reporting objective, and increasing the focus on operations and compliance. Technology is now embedded in business and affects all aspects of internal control. The updated framework considers how technology impacts risks and controls across the five components. Attendees were encouraged to review and
Steps for setting up Internal Audit Function / Department in Small / Medium S...Pritesh Hirapara
How to set up internal audit department in India, Strengthen Internal Audit Department, Internal Audit Department for Small and Medium size company in India.
This document provides an overview of internal audit strategy and risk approach for not-for-profit organizations. It discusses the context and challenges not-for-profits face, conceptual frameworks for internal control and governance, a practical internal audit model, resourcing strategies, the internal audit process, and integrating risk management. It proposes a risk-based internal audit approach and roadmap for developing an enterprise risk management framework that embeds risk management into operations. The document is intended to help not-for-profits design and implement an effective internal audit and risk management function.
Fixed Asset Controls and Reporting: Who's Paying Attention to Your Largest As...Duff & Phelps
Often an element of fraud and financial
misstatement, fixed assets get no
respect. Although they’re considered
low risk by auditors, fixed assets need
attention. Are the internal controls really
effective over this perceived low-risk
area? Best practices enhance proper
accounting, valuations and financial
reporting.
An effective compliance program has several key components: conducting a legal risk assessment to identify areas of focus, ensuring the program meets regulatory guidelines, tailoring the program to a company's unique operations, establishing standards and procedures to minimize risks and demonstrate commitment to ethical conduct, and providing training, monitoring, reporting, and investigations to foster a pro-compliance culture. An effective program is process-oriented, integrated into daily operations, and subject to continuous improvement.
There are five main pillars considered critical for building an effective internal audit function in the public sector: perception and ownership, improved processes and governance, legislative support, improved incentives, and commitment to change. Internal auditing has shifted from simply ensuring compliance to adding value by reviewing management procedures and focusing on efficiency and effectiveness, though this requires changes to culture and priorities. Factors like independence, understanding organizational issues, responsiveness, and implementing recommendations impact the internal audit function's effectiveness.
This competency map summarizes Walter Ostrander's coursework in the MBA6014 Financial Accounting course. He has completed all assignments at the distinguished level, demonstrating mastery of accounting theories, practices, and financial statement preparation. The map outlines five competencies, including applying accounting concepts, examining regulatory and ethical issues, integrating accounting across organizations, analyzing financial information, and communicating professionally. For each competency, the document lists multiple assignments addressing topics such as inventory, bonds, internal controls, and cash flow statements.
Auditing Cayman Funds and Crypto FundsDavid Walker
Presentation by Moore Stephens Cayman for the Cayman Islands Institute of Accountants on International Standards on Auditing for Cayman Funds & Cryptocurrency Funds
The document discusses financial management techniques for evaluating energy efficiency investments. It introduces concepts like simple payback period, return on investment, net present value, and internal rate of return. It explains how to calculate each metric and compares their advantages and limitations. The key financial analysis techniques allow comparing energy efficiency project costs and savings over time to different investment alternatives.
The document provides an overview of the requirements for non-profit organizations receiving over $500,000 in federal awards to undergo an A-133 audit. It discusses determining major programs, applicable compliance requirements, internal controls, and procedures auditors will perform to test compliance with each requirement. The presentation also lists reference materials and websites for additional information on A-133 audit requirements and federal grants management.
Accretive Health - Quality Care - Health Care Quality AccretiveHealth
This document discusses Accretive Health's quality and care coordination initiative. It aims to optimize quality and financial results across episodes of care by strengthening relationships between hospitals, physicians, and payors. The initiative utilizes predictive analytics, workflow technology, and population health management infrastructure to continuously improve patient care. This is expected to generate savings that are shared among participating providers, payors, and Accretive Health. Oncology care is highlighted as an area of growing costs and complexity that can benefit from a coordinated, data-driven approach to care.
This document provides a summary of Sanjeev Kumar Jain's qualifications and work experience. It outlines his education which includes a CA, DISA, and M.Com. It then details his employment history working for Vodafone Mobile Services Ltd as a Senior Manager for over 7 years and for Vodafone India Ltd as a Deputy Manager for over 5 years in telecommunications. It highlights his key responsibilities and achievements in financial management and internal auditing.
The document discusses various aspects of budgeting including:
1. It defines budgeting and provides objectives such as assisting management with planning, coordinating, and controlling operations.
2. It discusses four aspects of the control process: developing plans, communicating plans, motivating people, and reporting performance.
3. It covers capital budgeting and long-range planning, evaluating capital investments, and techniques for analyzing capital project feasibility such as payback periods and accounting rate of return.
Dol audits on the rise are you prepared?SSDLaw2014
The document discusses potential Department of Labor audits of employers for compliance with wage and hour laws. It notes that DOL investigations have increased 42% from 2011 to 2012. Employers can be audited based on complaints, random selection, or as a follow up to a prior investigation. Noncompliance can result in civil monetary penalties, back wages owed to employees, fines, and even criminal sanctions for willful violations. The DOL has broad authority to subpoena records and question employees during investigations. The document provides an overview of key areas that are audited - overtime pay, exemptions from overtime, worker classification as employees vs. contractors, and recordkeeping requirements. It offers recommendations for how employers can review their pay practices in these
This document provides an overview of ERISA compliance requirements for employee benefit plans. It discusses filing Form 5500 annually, having proper plan documents like a summary plan description, and being prepared for potential audits from agencies like the Department of Labor. Filing deadlines and penalties for noncompliance are also reviewed. The presentation aims to help employers understand ERISA obligations and ensure their benefit plans would survive an audit.
The document provides information on Form 5500 updates including:
- When audited financial statements are required based on plan size and other rules
- Details on the small pension plan audit waiver requirements
- Guidance on when a filing is considered filed based on its status
- Changes to the 2015 Form 5500 edit checks including new tests
- Updates on Delinquent Filer Voluntary Compliance Program filings and Form 8955-SSA filings
- DOL enforcement actions for improperly prepared filings
Everything You Need To Know About DOL Auditsbenefitexpress
The document discusses Department of Labor audits of employer health plans to ensure compliance with the Affordable Care Act. It notes that the DOL has begun requesting audited plans prove compliance with various ACA requirements. It recommends that plan sponsors prepare for audits by documenting compliance efforts, retaining all relevant records, and having agreements with third parties to provide necessary records if audited. Failure to comply with the ACA could result in fines or lawsuits. The document also discusses ongoing DOL audits more generally and provides tips for dealing with an audit, such as educating oneself on requirements and having a plan to efficiently provide requested documents.
SterlingRisk and Stacy Barrow Present - Surviving a DOL AuditNicholas Toscano
Hosted by SterlingRisk and Presented by Stacy Barrow, Esq. from Marathas Barrow Weatherhead Lent LLP
Stacy Barrow, one of the nation's leading experts on the Affordable Care Act covered the following:
- Preparing for and avoiding a DOL Audit
- Navigating a DOL Audit
- ERISA
- Forms Reporting
- Checklist of Commonly Requested Documents
- DOL Enforcement
Navigate New Legislation: The Road Into 2017benefitexpress
As new regulations kick in for 2017 and ACA reporting season is coming to a close, review all recent legislative changes. This webinar focuses on what you need to know for your 2017 benefits strategy.
Learn about new legislation from DOL, HHS, IRS, and EEOC. ERISA attorney Larry Grudzien will cover all relevant rulings since his previous webinar and host an interactive Q&A with the audience.
The webinar discussed the impact of the COVID-19 pandemic on employee benefit plans and the CARES Act. It covered how the CARES Act affects retirement plans, fiduciary responsibilities for evaluating investments during volatile markets, managing participant anxiety, financial reporting considerations, and the top 10 most common errors plans encounter. The webinar was moderated by Alexander Reyes with panelists John Eusanio and Tiffany McGhee. Citrin Cooperman's Employee Benefit Plan practice was also introduced.
Why is it important to assist your client in the audit process and how can it impact you?
Assisting clients with the audit firm selection process can be an opportunity to add value to your client relationship
Vetting plan audit firms and correspondence may lead to valuable referral relationships
Save clients from the possible risk of fines and penalties
Possible co-fiduciary responsibility in selecting other plan service providers
How to develop a proactive approach for assisting clients with the audit process
This document summarizes a presentation on avoiding 401(k) and pension plan disasters. It discusses objectives like learning how to prevent costly mistakes when running retirement plans and what to do if problems occur. It outlines Department of Labor statistics and enforcement priorities such as fiduciary breaches. The presentation reviews recent court cases involving church plans and misconduct by service providers. It also provides tips on establishing strong internal controls, common plan mistakes, correcting errors, and the Department of Labor's correction programs.
This document provides an overview of preparing for an employee benefit plan audit. It discusses who the key players are in a benefit plan audit, including the sponsor, participants, trustee, plan administrator, custodian and service providers. It outlines the audit requirements for different types of benefit plans and discusses topics like understanding the auditor's responsibilities, internal controls, common audit findings and working with the auditor. The overall goal is to help plan administrators better understand the audit process and make the audit more efficient.
Retirement Plans Under Attack by Plan Participants and Government Agencies: A...Human Capital Media
The document provides information about an upcoming webinar, including details about listening to the audio and accessing resources. It states that a dial-in number will not be provided and listeners should use their computer speakers or headphones. Frequently asked questions are answered, noting that the presentation slides and recording will be available afterwards and certification may be obtained. The webinar introduction then provides background about the presenter before beginning the presentation on retirement plan risks and regulatory compliance strategies.
Your annual plan audit does not have to be stressful. We will review plan audit requirements and how you can best be prepared for your audit to make it a more efficient and less stressful experience. Specific areas will include common audit findings: coordinating information from your plan service providers; timely completing your auditor’s requests; and wrapping up the audit. We will also discuss your fiduciary responsibility and risk regarding your plan audit and why you should be concerned in having an experienced firm perform your audit.
This document provides an overview and agenda for a presentation on common 403(b) plan compliance issues and solutions. It begins with introductions of the presenter and his background and experience. It then outlines the IRS and DOL voluntary correction programs that can be used to resolve plan failures. The majority of the document details frequent plan document issues, operational errors, and governance problems that 403(b) plans encounter. It provides examples and recommends best practices for correction.
Retirement Plans: Managing Your Fiduciary ResponsibilitySecureDocs
The document provides information about retirement plan governance and fiduciary responsibilities. It discusses the importance of establishing clear roles, processes, and oversight for retirement plans to help ensure compliance and protect fiduciaries from liability. It emphasizes having the right people involved, clearly identifying duties, documenting formal procedures, and routinely monitoring activities. Well-documented governance helps fiduciaries fulfill their responsibilities and prepares plans for potential IRS or DOL audits.
This webinar provided a 401(k) and pension plan accounting and auditing update for plan sponsors, including management, accountants, and Human Resource professionals. In addition, the presentation provided an update on recent Employee Retirement Income Security Act (ERISA) criminal cases, the outcomes of those cases, and the prosecution.
The document provides guidance for plan sponsors on hiring an auditor for an employee benefit plan audit. It outlines fiduciary responsibilities for plan sponsors, when an audit is required, and the importance of hiring a quality auditor. A quality auditor can help identify errors, ensure compliance, and provide ongoing guidance and solutions to benefit the plan. The document recommends plan sponsors consider an auditor's experience level, team orientation, and ongoing involvement when selecting one.
Common 401(k) Plan Operational DeficienciesSkoda Minotti
The document discusses common operational deficiencies in 401(k) plans, including failing to amend plan documents for legislative changes, late remittance of employee deferrals and loan repayments, not making mandatory distributions according to the plan document, and using an incorrect definition of eligible compensation to calculate deferrals. It provides examples of each deficiency, how to identify and correct the issues, and tips to avoid common mistakes. The key points covered include ensuring timely adoption of required plan amendments, establishing controls for timely processing of deferrals and payments, reviewing mandatory distribution provisions, and annually verifying the proper definition of compensation.
The document provides information about an IRS audit of an employer's retirement plan. It discusses what areas the IRS may audit, including plan documentation, qualification requirements, prohibited transactions, plan operations, assets, taxes, and reporting. It also notes that the audit process for large plans with over 2,500 participants (EPTA cases) involves more pre-audit analysis, use of specialists, and requests for electronic data. The document compares the Self-Correction Program (SCP), Voluntary Correction Program (VCP), and Compliance Assistance Program (CAP) that employers can use to correct retirement plan failures.
Clark Schaefer Hackett created this buyer’s guide to help you and other plan fiduciaries make an informed decision when hiring a quality auditor for your employee benefit plan audit. This guide covers your fiduciary responsibilities, the timing of a plan audit, audit quality, finding the right auditor and more.
www.Kay Sohl Consulting.org How an Auditor Looks at In.docxodiliagilby
www.Kay Sohl Consulting.org
How an Auditor Looks at
Internal Control
NASCSP State CSBG Monitors Training
November 17, 2010
Workshop Leader: Kay Sohl
www.Kay Sohl Consulting.org
Session Focus:
• Role & goal of independent audits
• Why auditors consider internal controls
• COSO framework
• System problems/implementation errors
• Testing controls & compliance
• Reports & findings
www.Kay Sohl Consulting.org
Quick Quiz?
1. What’s the purpose of an independent
audit of financial statements?
2. How is an A-133 audit different from a
“standard” audit of financial statements?
3. Who can conduct independent audits
and/or A-133 audits?
www.Kay Sohl Consulting.org
Independent Audits
• Board engages CPA to conduct
independent audit
• Management responsible for preparing
accurate financial statements
• Auditor responsible for opinion on extent
to which readers can rely on the
statements
www.Kay Sohl Consulting.org
Purpose of Independent Audit
Get auditor’s opinion about whether the
entity’s financial statements fairly present
the financial position and results of
activities in accord with standards of US
GAAP
www.Kay Sohl Consulting.org
Essential Requirements for
Auditors
• Independence
• Professional competence
• Sufficient study & testing to form basis for
opinion
• Work & communication in accord with
Generally Accepted Auditing Standards
www.Kay Sohl Consulting.org
GAAS
• Generally Accepted Audit Standards
• Developed by AICPA
• Published in Statements on Auditing
Standards (SAS)
• Significant changes since 2006
www.Kay Sohl Consulting.org
New Auditing Standards
• Require more rigorous analysis of risks
of misstatement and design of audit
procedures to test for significant risks
• Require disclosure to the board of
material weaknesses and significant
deficiencies
www.Kay Sohl Consulting.org
All Audits Require Auditor to:
• Understand the nature of the “business”
• Assess risks of misstatement &
noncompliance
• Understand controls to address risks
• Test controls
• Analyze results of test
• Determine significance of problems
www.Kay Sohl Consulting.org
Yellow Book Audits
• Government Auditing Standards
http://www.gao.gov/govaud/ybk01.htm
• Guides audits of individual federal
awards when A-133 not required
• Contains core requirements used for A-
133 audits
http://www.gao.gov/govaud/ybk01.htm
www.Kay Sohl Consulting.org
A-133 Audits
• Required when combined federal expenditures of
$500,000 or more within the organization’s fiscal
year
• Described in Office of Management & Budget
Circular A-133
• Include all standard independent audit procedures
and reports
• Require additional testing and reporting on
compliance with federal funds requirements
www.Kay Sohl Consulting.org
A-133 Audits- continued
• Include auditor’s opinion on compliance
wit ...
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This document summarizes a presentation given by Dunkin' Brands, Inc. on benefits auditing using Oracle Advanced Benefits. It implemented Oracle HRMS applications including Advanced Benefits in November 2007. Initial challenges included being new to the Oracle HRMS suite and lack of controls. The presentation highlights the need for auditing benefits configurations, life events, vendors, backfeeds, deductions, and adjustments. It demonstrates a custom Benefits Audit Workbench tool developed by Dunkin' Brands to proactively audit deductions and earnings, increase paycheck accuracy, and reduce employee issues. The tool identifies issues like flex spending account and deduction trending anomalies and missing initial payments.
This document provides an overview of auditing and assurance services. It defines auditing and distinguishes it from accounting. It describes different types of audits, the need for auditing, and the framework of auditing. It discusses the benefits of financial statement audits, limitations of external audits, and the development of auditing over time. It also covers topics like the principal-agent relationship in auditing, major corporate accounting crises, roles of auditors and users, requirements for becoming an approved company auditor in Malaysia, and the Sarbanes-Oxley Act passed after the Enron scandal.
Accounting involves creating financial statements and other information for management decision making, while auditing enhances the credibility of financial statements through an independent examination and evaluation of accounting records to form an opinion. A key difference is that auditors must have accounting knowledge and expertise to analyze audit evidence and accumulate audit findings.
Understanding Single Audit Compliance Requirements - It's No Joke!Citrin Cooperman
Has your not-for-profit organization received federal funding or additional funding under the CARES Act? This informational session discussed audit requirements for organizations receiving federal funds (i.e. Single Audits), reporting considerations, and specific requirements relative to COVID-19 response funds, including Paycheck Protection Program loans, Economic Injury Disaster Loans, Provider Relief Funds, and more.
Similar to Aicpa cu conference 2012 concurrent session 16 (20)
This document provides an agenda for a two-day Supervisory & Audit Committee Development Seminar on June 13-14, 2016. The agenda covers topics such as the unique role of credit union supervisory and audit committees, fundamental cooperative and credit union governance principles, and crafting an effective supervisory and audit committee for the future. The seminar will be facilitated by Michael G. Daigneault of Quantum Governance, L3C and Allen P. DeLeon of DeLeon & Stang CPA firm and include presentations, exercises, and discussions.
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The document summarizes the key points of ASU 2010-20, which establishes new disclosure requirements for the credit quality of financing receivables and the allowance for credit losses. It requires additional disclosures regarding impaired loans, delinquency aging, roll forward of allowance by portfolio segment, credit quality indicators by class, and troubled debt restructurings. The new standard is effective for calendar year-end 2011 for non-public entities. Credit unions will need to enhance their processes and systems to capture the additional disclosures required for the financial statement footnotes and NCUA call reporting.
The document discusses the results of a study on the impact of COVID-19 lockdowns on air pollution. Researchers found that lockdowns led to significant short-term reductions in nitrogen dioxide and fine particulate matter pollution globally as human activity declined. However, the impacts on air quality were temporary and pollution levels rebounded once lockdowns were lifted and activity resumed.
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These materials are perfect for enhancing your business or classroom presentations, offering visual aids to supplement your insights. Please note that while comprehensive, these slides are intended as supplementary resources and may not be complete for standalone instructional purposes.
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Aicpa cu conference 2012 concurrent session 16
1. AUDITING PENSION PLANS: TOP
10 MOST COMMON AUDIT FINDNGS
and OVERVIEW OF DOL INITATIVES
AFFECTING PLAN AUDITS
Concurrent session 16
Allen P. Deleon, CPA – DeLeon & Stang, CPAS &
Advisors
Ian Dingwall, CPA - Chief Accountant
DOL
Employee Benefits Security Administration
2. 401k Plan Auditing Concerns and Issues
Allen P. DeLeon, CPA
Founding Partner, Deleon &
Stang, CPAs and Advisors
Member of the AICPA Credit
Union Conference Planning
Committee and the AICPA
Benefit Plan Audit Quality
Center
Chair, Maryland Association
of CPAs
Contact information:
• 301-948-9825
• allen@deleonandstang.com
• @allendeleon
2
3. BASIC OVERVIEW OF A 401k PLAN AUDIT
A 401k plan is a type of defined contribution plan, which
means that the participants account balance equals his
plan benefits.
A “qualified” plan established by employers to which
eligible employees may make “salary deferral”
contributions on a post-tax and/or pre-tax basis.
“Qualified” means meets the standards set forth in
section 401, paragraph (k) of the Internal Revenue code.
“Salary deferral” is money that is deducted from your
paycheck before taxes are withdrawn. Some plans do
allow you to contribute money on an after-tax basis as
well.
4. FEATURES OF A 401k PLAN
Participant data Salary deferral
• Eligibility Employer match
• Auto enrollment
Roth contributions
Contributions Testing 415 (c) limits
Contribution limits ADP/ACP testing limits
• Increasing limits EGTRRA
Timeliness & reporting
• Catch up contributions
• Rollover
Vesting & forfeiture
Eligible compensation
Portability
4
5. FEATURES OF A 401k PLAN (CONTINUED)
Investments Other
• Elections (participant • Participant loans
directed vs. non-participant • PII
directed) • PT’s
• Frequency of changes to • Expenses and new
elections reporting
• Types of investments
• Valuation methods (daily
valuation)
Benefit Payments
• Distributions
• Timing
• Rollover
• Reporting
5
6. WHAT IS DIFFERENT ABOUT 401k PLANS
Employee contributions can vary, up to the
maximum allowed by law ($16,500 for 2012)
Employee contributions are made pre-tax
Many employers will match a portion of employee
contributions
Investment earnings are tax deferred until withdrawn
at retirement age.
An excise tax penalty is imposed if distributions are
taken from the plan prior to retirement age (591/2)
8. KEY PLAYERS AND ROLES
Plan Sponsor – employer and decides on plan
features
Plan Administrator – responsible for operation of the
plan. Can be employer or third party
Custodian/Trustee- Hold plan assets in trust
Record-keeper- maintain participant accounts,
prepares 5500 etc..
Oversight Agencies-
• Department of Labor (DOL)
• Internal Revenue Service (IRS)
9. INITIAL OR FIRST TIME 401k PLAN AUDIT TIPS
Engagement letter
Communicate with predecessor auditor and
review work papers
What type is audit is required? Full or limited
scope?
Who are the service providers
• Trustee
• Record keeper
• Sponsor
10. INITIAL OR FIRST TIME 401k PLAN AUDIT TIPS
(continued)
Risk assessment and get a feel for the
quality of records and what SOC reports are
available
Read plan document and amendments and
understand the plan
Opening balances:
• What procedures need to be performed?
• Participant data
11. MOST COMMON EBP PLAN AUDITING
MISTAKES
< 100 participants? Is an audit necessary?
Full scope audit vs. limited scope audit? What is the
difference?
Too much reliance on SOC reports
Contributions based on correct plan definition of
compensation?
Supplemental schedules:
• Delinquent participant contributions
• Assets held
• 5% reportable contributions
12. Limited Scope vs. Full Scope
Audit Procedures Limited Scope Full Scope
Confirm assets directly with custodian X
Agree the certified investment information to X
the Plan’s financial statements
Year-end market value testing and leveling X
Investment transaction testing X
Test investment income allocation to X X
participants
Determine that the Plan’s financial statement X X
and disclosures are in compliance with GAAP
13. MOST COMMON EBP PLAN AUDITING
MISTAKES
No or limited fraud assessment – Examples of EBP
Fraud
• Eligibility – person entered into the HR system and enrolled into
the plan who never actually began work
• Fictious employee who then took out 401k plan loans
• Participant who faked his death to get money out of the plan
• HR employee who handled both plan contributions and payroll
and reconciled payroll bank account diverted money to personal
accounts
• HR director made changes to employer contributions before
submitting file to TPA
14. MOST COMMON EBP PLAN AUDITING
MISTAKES
No or limited fraud assessment – Examples of EBP
Fraud (continued)
• HR employee manually processed participant statements to hide
loans
• Employee said car loan was for home purchase to get longer
amortization period
• Plan administrator used forfeiture account to pay personal credit
card expenses.
• Plan administrator paid himself by setting up a fake vendor and
paying himself and approving invoices.
16. DOL Initiatives Affecting Your EBP Audits
Ian Dingwall, CPA
Chief Accountant
DOL
Employee Benefits
Security
Administration
The views expressed are those of the speaker and do not
necessarily represent the official position of the Department
17. Overview of DOL Initiatives Affecting
Employee Benefit Plan (EBP) Audits
DOL Current Focus
EBSA Audit Quality Initiatives
Fraud in EBPs
Regulatory Initiatives
18. What is EBSA’s Current Focus?
High Risk Audit Engagements
Multi-employer Plans
• Defined Benefit Pension Plans
• Defined Contribution Pension Plans
Single Employer Defined Benefit Pension Plans
Health and Welfare Plans
ESOPs
403(b) Plans
18
19. ESOPs
Over 50% of audits contained deficiencies
Common audit deficiencies include:
• Failure to identify valuation of employer stock in the
risk assessment
• Review of the work of the appraiser (full scope audits)
• Testing the release of shares from the suspense
account
• Testing benefit payments
• Obtaining and reviewing documentation of stock
purchases
• Party-In-Interest = inadequate or no audit work
performed 19
20. 403(b) Plan Audits
Review of 84 sets of 2009 403(b) plan audit
work papers
Firms of all sizes
Opinions varied and included
• Clean limited-scope
• FAB language
• Recordkeeping language
Work on opening balances varied greatly
What will OCA deem rejectable?
20
21. Reporting Compliance Initiatives
• Electronic Communication
w/Filers
• Schedule C Compliance
• Reporting of Funded Welfare
Plans
• Missing IQPA Reports
• Collaboration w/IRS & PBGC
21
22. EBSA Audit Quality Initiatives
Firm Inspections
Mini Inspections
Small Practice Reviews
23. CPA Firm Inspection Program
Review EBP practice of firms that perform significant
number of plan audits or that audit significant
amount of plan assets
Similar to PCAOB Inspections
Review policies and procedures
Review audit work papers of selected audit
engagements
24. CPA Firm Mini Inspections
Focus on CPA firms that perform between 100-199
plan audits
No initial onsite visit
Questionnaire to CPA firm
Assess overall firm structure and control
environment
Select a sample of audit engagements for detailed
review
25. Small Practice Reviews
Focus is on firms performing a small number of EBP
audits
EBSA Office of Chief Accountant reviews
workpapers of selected audit areas
Scope of review may be expanded
Reviews performed in-house
26. What To Expect From Us
Inquiry letter to plan administrator
Review of audit workpapers
Statement of Preliminary Findings
Rejection of plan filing
Assessment of civil penalties
Referral to AICPA/state regulators
28. EBP Audit Best Practices
Commitment to Quality
• Executive Level
• Firm-wide
Importance of EBP Audit Practice
• Focal point within firm
• Realistic audit fees
• Comprehensive EBP specific resources
Internal Inspection Programs
Use of Internal Experts
29. Fraud in EBP
“Sandhogs” Union Local 147
• $40 million embezzlement by fund administrator
DOL Criminal Enforcement Cases
• News releases at
http://www.dol.gov/ebsa/newsroom/criminal/main.html
DOL’s expectations and auditor’s responsibilities
31. Informed Decision Making and Excessive
Fees – The Three Legged Stool
Disclosures by plans to participants of certain plan
and investment-related information – Interim Final
10/20/10
Disclosures to plan fiduciaries to assist in assessing
408(b)(2) reasonableness of compensation and
potential conflicts of interest – Interim Final 7/16/10
Disclosures to public and government on
electronically filed Form 5500 Annual Report
including indirect compensation – Form 5500,
Schedule C
32
32. Fee & Expense Disclosures – Plan to
Participant (ERISA §404)
Effective – plan years beginning on or after 11/1/11
Requires fiduciaries to:
Give workers quarterly statements of plan fees &
expenses deducted from their accounts
Give workers core information about investments
available under the plan
Use standardized methodologies when calculating
and disclosing expense and return information
33
33. Fee & Expense Disclosures – Plan to
Participant (ERISA §404) (continued)
Centerpiece – a requirement to provide investment-
related advice in a format that permits workers to
comparison shop among investment options
DOL has developed a model chart for complying with
this requirement
The reg., model chart, and fact sheet may be viewed
at www.dol.gov/ebsa
34
34. Fee & Expense Disclosures – Service
Providers to Plans (ERISA §408(b)(2))
Brings new transparency to the process of selecting
and monitoring of plan service providers
Establishes comprehensive disclosures from
service providers concerning services, fees, and
potential conflicts of interest
Applies to plan contracts or arrangements for
services in existence on or after 7/1/12, extended
from 7/16/11, 1/1/12 and 4/1/2012
Applies to covered service contracts ≥ $1,000
35. ERISA § 404 Disclosures – Initial
Implementation Dates
First disclosure dates follow the
effective date of the 408(b)(2) regulation
Initial annual chart disclosure of “plan
level” & “investment-level” info –
8/30/12
First quarterly statements – 11/14/12
Clients need your pro active help 36
36. Clarification of the Meaning of “Reasonable
Arrangement” in 408(b)(2) Disclosure Rules
All service agreements must be in writing (no
prescribed format)
Impose new service provider disclosure
obligations before or at the time the plan enters a
service agreement
37. 408(b)(2) Disclosure Rules – Covered Service
Providers
Persons who provide services as an ERISA fiduciary
or under the Investment Advisors Act of 1940.
Persons who provide certain recordkeeping or
brokerage services and make available investment
options to be offered by the plan
Persons who receive or may receive indirect
compensation for the following services:
accounting, auditing, actuarial, appraisal, banking,
consulting, custodial, insurance, investment
advisory (plan or participants), legal, recordkeeping,
brokerage, TPA, or valuation
38. 408(b)(2) – Required Disclosures
Service providers are required to disclose (before
the parties enter into an agreement for services):
• All services to be provided under the agreement
• The compensation or fees to be received for each
service
• The manner of receipt of compensation or fees
• Information about conflicts of interest.
Establishes disclosure burden on service provider –
integrated with 2009 Form 5500 Schedule C
Reporting
39. Consequences of Non Disclosure =
Prohibited Transaction
Contract or arrangement will not be “reasonable”
and violates 408(b)(2)
Responsible Plan Fiduciary violates 406(a)(1)(c) by
participating in the prohibited transaction.
Reportable on Schedule G
Service provider is a “disqualified person” under IRS
prohibited transaction rules and is subject to excise
taxes under Code section 4975
40
40. Investment Advice
Final rule published in the Federal Register – October 25,
2011
Designed to improve participant access to fiduciary
investment advice
Permits a fiduciary investment adviser who receives
additional fees from investment providers if certain
conditions are met
• Use of a computer model that is certified as unbiased by
an independent expert or
• Through an adviser compensated on a “level-fee” basis,
meaning that the fees do not vary based on investments
selected
May be viewed at http://s.dol.gov/J4
41
41. Definition of Fiduciary Project
DOL intends to re-issue proposed rule
The purpose of the reg. is to ensure that potential
conflicts of interest among advisors do not
compromise the quality of investment advice
The proposed reg. would more broadly define
“fiduciary” when a person provides investment
advice
42
42. Definition of Fiduciary Project - Continued
Revisions are likely to:
• Be limited to individualized advice directed to specific
parties
• Address concerns about the effect of the reg. on routine
appraisals and arm’s-length commercial transactions
Anticipated exemptions will:
• Address current fee practices of brokers and advisors
• Clarify that longtime exemptions that allow certain
commissions will still apply
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43. Interim Policy on Electronic Disclosures
Technical Release 2011-03
Expands the ability of plans to use electronic disclosure
requirements under DOL’s final participant-level fee disclosure
regulation
Allows plan administrators to furnish information electronically
while ensuring that all employees will benefit from the
regulation’s increased transparency
Includes the use of continuous access websites if certain
conditions and safeguards are met
DOL will not take enforcement action solely based on a plan
administrator’s use of electronic technologies
Please see: www.dol.gov/EBSA/pdf/tr11-03.pdf
44. Guidance for Apprenticeship & Training
Programs – FAB 2012-01
Issued 4/2/12
Provides guidance regarding plans paying
graduation ceremony and advertising expenses
Certain “modest” graduation ceremony and
outreach expenses are permissible
Violations more prevalent where plans lack written
expense policies & internal controls
OLMS has published a list of useful internal controls
45. Reporting Compliance Initiatives
• Electronic Communication
w/Filers
• Schedule C Compliance
• Reporting of Funded Welfare
Plans
• Missing IQPA Reports
• Collaboration w/IRS & PBGC
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