Certification: 29 C.F.R. 2520.103-5

[Guest richez]

One of my new clients is requesting a Certification, 29 C.F.R. 2520.103-5. What is this and what does it do for my client? Can anyone point me to any guidance so I can read up on this? His auditor says that without it, they will have to have a full audit, not just a limited scope audit.

[WDIK]

http://www.dol.gov/dol/allcfr/Title_29/Par...R2520.103-5.htm

See subsection (d).

[Leopurrd]

Basically its your certified statement from the custodian that should go along with their SAS 70. It allows the auditor to rely on the SAS 70 report, so the custodian's controls won't need to be tested by the plan's auditor. (Hence the term "limited scope").

If you're just the TPA and not the custodian (which i'm guessing is correct since you're asking this question), you'll need to ask the custodian for their SAS 70 and certification, and forward it onto your client or their auditors. Not every institution may have one, though. I've ran into some smaller plans with brokerage accounts that do not provide a SAS 70/certification since it was not on their recordkeeping platform.

Vicki