DOL Request for Plan's IQPA Workpapers

[401 Chaos]

We have a client who received an Audit Letter from the DOL's Office of Chief Accountant in Washington, D.C. requesting copies of all audit workpapers and other documents within the independent auditor's possession that support the audit procedures performed with respect to investments, contributions, benefit payments, participatn data, plan obligations, and prohibited transactions. The letter simply notes that the request is being made as part of an "ongoing program" by the DOL to ensure compliance with ERISA's plan audit requirements.

I am curious if others have received similar requests and this is likely just an ongoing program and the client got audited at random or whether it is likely that something on the Form 5500, a participant complaint, or other issue triggered this request. Other audits we have seen that have been sparked by participant complaints have generally originated from the DOL's Regional Office and the client is not aware of any problems or complaints that would have sparked this. Thanks in advance for any thoughts.

[BeckyMiller]

In response to a IG report, the DOL has begun a new procedure for auditing the auditors. There are two approaches being taken based upon the number of plans audited by a particular firm. For firms that audit few plans, the letter that you described is being sent. This request was based upon a random selection of the list of accounting firms who audit 5 or fewer plans.

For auditors of more plans, a more detailed review is to be performed of their policies and procedures, training, etc. regarding the audit process.

See http://conferences.aicpa.org/ebp05/downloads/ses03.pdf

for an outline from the Office of Chief Accountant, EBSA for a discussion of this process.

[401 Chaos]

Becky,

Thanks very much. That makes me feel somewhat better... I think. Although I suppose there could be still be something about this plan that has gotten flagged for audit as part of the new program rather than their selection being completely random.

Interesting breakdown of the number of auditors and plan audits they perform. Reading between the lines, it would seem that there are roughly 1,763 or so auditors out there that perform between 5 and 100 plan audits which is where I believe our auditor generally falls although I'm not sure exactly how many they do.

Thanks again.