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DB plan with post-10/15 contributions - auditor thoughts?

Bug on my window

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Hi Folks,

I'm looking for some input from folks smarter than me. :)

How will auditors look at plans with post-10/15 contributions for the 2019 plan year? Specifically, I'm assuming that these contributions are not reported on the 2019 SB (since they haven't been made yet) as of the time of filing. Will they be left off of the audit report? Included as a footnote? If the plan sponsor amends the filing post-10/15 to include the contributions on the SB, will the H/audit also require amendment?

Thanks for your thoughts on this!


The above is my opinion only, not anyone else's.

I'm not a lawyer nor do I play one on TV.

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They should be reported on lines 1b(1) and 2a(1)(A) of Schedule H. Unlike the Schedule SB, you can include contributions on the Schedule H even if they haven't been made at the time the 5500 is filed. Therefore, if you know in advance what the contribution is going to be, you can report it on the Schedule H when you file it on or before 10/15.

However,  since you will have to amend the filing anyway once the final contribution is made, I don't see the point.

As far as the audit report, you will have to discuss that with the auditor.

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.

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