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| SAS No. 136 Illustrative Auditor’s Reports, Retroactively Adopted Plans Form 5500 Filing Requirements, and FASB Agenda Request |
| September 10, 2021 — EBPAQC Alert No. 476 |
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| Dear Center Members: |
This alert contains information on:
- SAS No. 136 Illustrative Auditor’s Reports,
- Retroactively Adopted Plans Form 5500 Filing Requirements, and
- FASB Agenda Request.
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Illustrative Auditor’s Reports for Initial Year of Implementation of SAS No. 136
The AICPA has issued an EBP industry FAQ with illustrative auditor’s reports for the initial year of implementation of AICPA Statement on Auditing Standards (SAS) No. 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, as amended (EBP SAS). The document was prepared by AICPA staff to provide nonauthoritative guidance to assist practitioners as they implement the EBP SAS in their ERISA audits for the first time.
The FAQ addresses what the auditor’s report will look like in the first year, whether the auditor is the continuing auditor or if they are a successor auditor.
Click here to access the Employee Benefit Plans Industry FAQ with Illustrative Auditor’s Reports for Initial Year of Implementation of SAS No. 136, as Amended.
Form 5500 Filing Requirement for Plans Retroactively Adopted After the End of the Plan Year
The August 6, 2021 IRS Employee Plans newsletter explains that plans retroactively adopted under Section 201 of the SECURE Act, which permits an employer to adopt a retirement plan after the close of the employer’s taxable year and elect to treat the plan as having been adopted as of the last day of the taxable year, have no 2020 Form 5500 filing requirement. The first Form 5500 required to be filed with respect to the plan will be the 2021 Form 5500, and the plan sponsor will be required to check a box on the 2021 Form 5500 indicating that the employer elects to treat the plan as retroactively adopted as of the last day of the employer’s 2020 taxable year. Retroactively adopted defined benefit plans will be required to attach a 2020 Schedule SB to the 2021 Form 5500 or Form 5500-SF, in addition to a 2021 Schedule SB.
The instructions for the 2021 Form 5500 will further explain the filing requirements for plans adopted retroactively. In addition, it is expected that similar rules will apply to the retroactive adoption of a plan pursuant to section 201 of the SECURE Act after an employer’s 2021 taxable year.
Click here to read the August 6, 2021 IRS Employee Plans newsletter.
FASB Agenda Request
The AICPA Financial Reporting Executive Committee (FinREC) has submitted an Agenda Request to ask that the FASB add three EBP related topics to its Technical Agenda. FinREC has requested that FASB consider providing guidance on the accounting for:
- funding credit balances in a defined benefit pension plan,
- employer contributions receivable in defined benefit pension plans, and
- employee and employer contributions receivable for a single employer defined contribution plan.
Click here to read the Agenda Request.
Sincerely,
AICPA Employee Benefit Plans Audit Quality Center |
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