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Posted

A client's 401(k) Plan is undergoing an IRS audit and the auditor requests both an Allocation Schedule and a report of 401k contributions for each pay period. 

Anyone know the difference, or what exactly they're looking for in an allocation schedule?

R. Alexander

Posted

I would guess that the allocation schedule is for the employer contributions, whether it be match, nonelective etc. It would show how the employer contribution is calculated or the basis for the employer contribution amounts. 

For example, if an employer does a year-end profit sharing contribution and the contribution is pro-rata, I would expect a list of everyone's plan compensation, and the employer contribution amount, so that the auditor could cross check it. I would expect the auditor to check that the compensation used for the employer contribution is accurate based on the amounts reported on payroll records and the plan document, and that the allocated contribution conforms with the plan document methodology (match formula, profit sharing formula etc). 

Just because an employer deposits an employer contribution each pay period doesn't mean the information about how that contribution is calculated is on the payroll reports. If it isn't then whatever separate allocation report / schedule should be provided. 

You could just ask the auditor. I have found most to be very reasonable and agreeable. 

I'm a stranger on the internet. Nothing I write is tax or legal advice. 

I'd like a witty saying here, but I don't have any. When in doubt, what does the plan document say?

Posted

I am very old school (record kept 401k plans in the early 1990s) back when we did quarterly valuations and gave "allocation reports" to our clients every quarter along with the participant quarterly statements. With the influx of daily valuations, many recordkeepers stopped the consistent allocation reports, but should be able to provide one out of their transaction based system between any two dates if you ask.  

We had to get these for our IRS audit and our recordkeeper pulled a "Participatn Aggregate Rollup Statement" on a Cash basis by money source and investment option. The columns were (beginning balance, contributions, exchanges, forfeitures, loans/withdrawals, loan principal repay, loan interest repay, gain/loss, adjustments and ending balance)

A payroll report is only going to have contributions/deferrals and loan payments (possibly not split by principal and interest).  

Posted

Allocation schedule is from the RK showing all the contributions allocated to participant accounts.

Payroll report might only show salary deferrals (loan repayments, safe harbor and match are possibilities). 

Auditor wants to verify what was withheld for a participant was allocated to the participant.

Kenneth M. Prell, CEBS, ERPA

Vice President, BPAS Actuarial & Pension Services

kprell@bpas.com

Posted
1 hour ago, CuseFan said:

Allocation schedule is from the RK showing all the contributions allocated to participant accounts.

 Payroll report might only show salary deferrals (loan repayments, safe harbor and match are possibilities). 

 Auditor wants to verify what was withheld for a participant was allocated to the participant.

That makes perfect sense. Thank you.

R. Alexander

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