Small plan needs audit?

[Flyboyjohn]

Surfing the EFAST2 website came across a 5500 Schedule I (Small Plan) reporting:

3a $900,000 of Parnership/Joint Venture interests

4e $500,000 Fidelity Bond

4k Claiming qualification for audit waiver

Since the bond is less than the non-traditional assets doesn't this plan have to have an IQPA audit?

[Kevin C]

Maybe yes, maybe no.

Some or all of the line 3a could be qualifying assets under §2520.104-46 (b)(1)(ii). Non-traditional assets are not automatically non-qualifying assets.

The non-qualifying assets could be less than 5% of plan assets as of the beginning of the year. The bond requirement only applies if the qualifying assets are less than 95% of plan assets.