Plan Audits on termination

[erisageek1978]

Employer going out of business that has two plans: 403B and a pension plan (assume 100 participants or more).  The 403B plan year is the calendar year.  The pension plan year ends on June 30.  Is the employer required to have an audit performed for each plan for the following time periods? 403B for CY2024 (plan terminated 7.31) ( I believe YES) and pension plan for plan year ending June 30,2025 (I assume also YES). Thanks.

 

 

[Peter Gulia]

That the plan is discontinued or even ended, or that the employer dissolves, is not an excuse from ERISA § 103’s command for an audit of the plan’s financial statements.

Consider whether a plan-accounting year ends when the plan pays or delivers the plan’s final distributions.

For each plan, consider whether the employer or the plan needs a reserve of amounts to pay the independent qualified public accountant’s fee.