Schedule C - Change in auditors

[Guest Christie Banks]

Does anyone know if there is specific wording the DOL likes to see on Schedule C, when there is a change in plan auditors?

[JohnCheek]

When I have filled in the Sched C, I have been more comfortable when I could report the prior auditor was retiring, or the trustees found an auditor with more experience in ERISA audits (that's me), or some other explanation that did not necessarily raise a red flag. Changing because of fee considerations would also be un-remarkable.

Once I asked a trustee what explanation he wanted me to put down, and he said the fund changed because "Vinny (my former partner) was a better golfer". I assumed he meant to say something about the new firm having more relevant experience, so that's what I wrote.

I have not heard directly from the DOL, but I imagine they don't like words like "fraud", "missappropriation", "collusion", etc. They probably are also unhappy if the explanation implies "opinion shopping", ie, the plan relpaced the old auditors because the new guys would agree to an accounting treatment that the management wanted.

Of course, in the end, the explanation on Schedule C must be truthful, even if it is a bit embarassing to someone.