| Dear Center Members: |
This alert contains information on:
- Form 5500 Instructions for Accountant's Opinion;
- AICPA EBP Volunteer Opportunities and Committee Changes
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DOL staff clarifies 2020 Form 5500 Instructions for Schedule H Part III - Accountant's Opinion
While speaking at the 2021 AICPA Employee Benefit Plans Conference, Michael Auerbach, Chief Accountant of the DOL's Employee Benefit Security Administration, stated that, while the DOL has not issued clarifying guidance on how to report the type of accountant's opinion on Schedule H Part III - Accountant's Opinion of the 2020 Form 5500, if SAS No. 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, is not early adopted for 2020 plan year audits, the DOL staff's preferred treatment is for preparers to check line 3a as "Unmodified" (box (1)) and to check the box on line 3b based upon the scope of the plan's audit. However, the DOL staff recognizes that some firms are not comfortable checking "unmodified" if they have issued a limited scope disclaimer opinion and, in such cases, the preparer may check "Disclaimer" (box (3)) on line 3a. Mr. Auerbach noted that while this treatment is not preferred, it will not, in and of itself, create an enforcement issue.
As reported in EBPAQC Alert #447, the AICPA Auditing Standards Board deferred the effective date of SAS No. 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, as amended, until periods ending on or after December 15, 2021, although earlier implementation is permitted. As of the date of the deferral, the instructions for the 2020 version of the Form 5500, Annual Return/Report of Employee Benefit Plan had already been revised to reflect the requirements of SAS No. 136. However, most firms are not early adopting SAS No. 136, which is creating confusion among Form 5500 preparers about how certain information related to the accountant's opinion and type of audit performed should be reported in Part III—Accountant's Opinion, Lines 3a and 3b, on Schedule H, Financial Information.
If the auditor adopts SAS No. 136 for the 2020 filing period, plan administrators, including plan management and third-party service organizations, should refer to the 2020 Form 5500, Schedule H instructions for lines 3a and 3b. [Note: SAS No. 136 no longer allows for a disclaimer of opinion solely if management elects to have an audit performed in accordance with ERISA Section 103(a)(3)(C) pursuant to 29 CFR 2520.103-8 of the Department of Labor's Rules and Regulations for Reporting and Disclosure under ERISA.]
As the changes made to lines 3a and 3b of Part III of Schedule H, and to the instructions for lines 3a and 3b, did not anticipate the deferral of SAS No. 136, they do not reflect the fact that auditors who did not early adopt SAS No. 136 will be issuing accountant's opinions using the current (pre-SAS No. 136) auditor reporting standards for the 2020 filing period.
Click here for the Form 5500 Series.
For additional questions, contact the DOL's EBSA Office of Chief Accountant at (202) 693-8360 (voice mail is being regularly monitored).
AICPA EBP Volunteer Opportunities and Committee Changes
2022-2023 AICPA Volunteer Committee Application Process Underway
If you are interested in contributing to the profession and networking with your peers, then consider applying to serve on the EBPAQC Executive Committee or the Employee Benefit Plans Expert Panel. The application period opens on June 1 for the next volunteer year (May 2022 – May 2023) and applications will be accepted until October 1, 2021. Volunteer committee applications can be accessed via https://volunteers.aicpa.org/default.aspx. Please be sure to provide a detailed resume along with your application that includes pertinent information about your EBP experience. To attach your resume, click on the Resume and Letters of Recommendation option under the Apply tab. If you have any questions regarding the application process or volunteering in general at the AICPA, email inquiries to AICPAVolunteerServices@aicpa.org.
Following is information about these volunteer opportunities and applicant qualifications.
EBPAQC Executive Committee
The EBPAQC Executive Committee establishes general policies of the Center and oversees its activities. The Executive Committee is made up of 16 members who may serve up to three consecutive one-year terms. The Committee comprises members from small, medium, and large firms from various geographic regions throughout the country. Candidates for the EBPAQC Executive Committee must be the firm's Center Designated Partner, have significant employee benefit plan audit experience, and the candidate's firm must be in compliance with all Center membership requirements. Candidates should also have demonstrated commitment to improving ERISA audit quality within their firm and be active in their state CPA society or other similar activities. Membership on the Executive Committee requires a minimum commitment of 125 to 150 volunteer hours per year. Committee members should be prepared to attend two in-person committee meetings per year and periodic committee conference calls, participate in the activities of two or three task forces, participate on EBPAQC webinars, and speak on behalf of the Center at various AICPA and state society conferences.
EBP Expert Panel
The Employee Benefit Plan Expert Panel monitors employee benefit plan industry developments, trends and opportunities to identify and advise on reporting, attest and assurance issues unique to employee benefit plans. The EBP Expert Panel is made up of 14 members who may serve up to three consecutive one-year terms. The Panel comprises members from small, medium, and large firms from various geographic regions throughout the country. Membership on the Expert Panel requires a minimum commitment of 75 to 100 volunteer hours per year. Candidates will be evaluated based on employee benefit plan audit experience, proven leadership qualities and skills, availability to participate in panel and task force activities, and active participation in their state CPA society or other similar activities.
EBPAQC Executive Committee Volunteer Changes
On behalf of the entire Center membership we would like to thank outgoing EBPAQC Executive Committee members Jennifer Allen, Crowe Horwath LLP; Monique Elliott, Elliott Group CPAs, PLLC; Travis Jack, Metz & Associates PLLC; and Beth Thompson, KPMG LLP, for their outstanding service on the committee and for contributing to the success of the Center during their years of volunteer service.
We welcome new Executive Committee members Nicole Hilbert, KPMG LLP, Cleveland, OH; Linda McLean, DiCicco, Gulman & Company LLP, Woburn, MA; Brian Price, PriceKubecka, PLLC, Addison, TX; and Emily Toler, Capin Crouse, LLP, Indianapolis, IN.
Continuing on the Executive Committee are Chair, Debbie Smith, Grant Thornton LLP, and members Doug Bertossi, CliftonLarsonAllen LLP; Sandi Carrier, Deloitte & Touche LLP; Beth Garner, BDO; Judy Goldberg, EY; Chip Harris, RubinBrown LLP; John Nicolopoulos, RSM USA LLP; Steve Perazzoli, PwC; Gwen Stoute, HoganTaylor LLP; Wendy Terry, WithumSmith+Brown; Lisa Todd, Moss Adams LLP, and David Torrillo, Torrillo and Associates, LLC. We thank all of these members for contributing a significant amount of volunteer time and energy in helping EBPAQC members and overseeing the activities of the Center.
Employee Benefit Plans Expert Panel Volunteer Changes
The AICPA Employee Benefit Plans Expert Panel consists of volunteers whose primary role is to identify emerging EBP accounting and auditing issues, recommend appropriate action in addressing the issues, assist in developing AICPA EBP resources, and provide technical support to the Center's Executive Committee by participating as speakers on webinars and in reviewing Center tools.
We would like to thank outgoing Expert Panel members Erin Breit, BDO; Michelle Buckley, Meaden & Moore; Greg Clark, Gregory M. Clark, CPA; Catherine Daubeck, Deloitte & Touche LLP; Kathleen McLaughlin, Grant Thornton; Roland O'Brien, CliftonLarsonAllen LLP; Beth Thompson, KPMG LLP, and Michele Weldon, PwC, for their service and contributions.
We welcome the following new members to the Expert Panel: Jennifer Allen, Crowe Horwath LLP, Columbus, OH; Kimberly Carl-Cooke, Deloitte & Touche LLP, Kansas City, MO; Jason Eddy, Grant Thornton, Boston, MA; Cathleen Finneran, PwC, Basking Ridge, NJ; Kathryn Long, Sikich LLP, Springfield, IL; Jodi Schmidt, KPMG LLP, Katy, TX; Calvin Upton, Briggs & Veselka Co., Houston, TX, and Tiffany White, Clark, Schaefer, Hackett & Co, Columbus, OH.
Continuing on the Expert Panel are Chair, Josie Hammond, RSM USA LLP; Darlene Bayardo, BDO; Judy Goldberg, EY; Jayme Malimban, Johnson Lambert LLP; Stacy Meyer, CliftonLarsonAllen LLP, and Tiana Wynn, SB & Company LLC.
Sincerely,
AICPA Employee Benefit Plans Audit Quality Center |
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