Info for Schedule of Reportable Transactions

[Guest Laura A]

Ok - got a question from an auditor. They're doing a full-scope audit, and have to review "reportable transactions," even though a Schedule of Reportable Transactions is not required (all investments are participant-directed).

Neither the client nor its recordkeeper has this information, and act like the auditor is crazy for requesting it.

My question (on behalf of the auditor) is this - when the new rules came out for what goes on the Schedule of Reportable transactions, was there also some guidance on retaining the information on the transactions (even though it doesn't get reported?) I can't seem to find anything on point.

Thanks!