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Plan Sponsor Also Acts as Plan's Asset Custodian -- Is the Plan Required to Be Audited?
BenefitsLink Message Boards 
Apr. 28, 2021 "Our client (ABC bank) is sponsoring a pension plan with 85 participants. ABC bank also holds the investments and some of the assets are invested in the ABC money market fund. The auditor stated that because the ABC bank holds the investments (they are the trustee and custodian), the plan is required to be audited. The fact that the plan sponsor is also the custodian might be a potential fiduciary issue (prudent rule) but that should not preclude the plan sponsor from waiving the audit requirement. Agree?"
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