SAS 136 – Steps to Determine if an ERISA Section 103(a)(3)(c) Audit is Permissible

During the Summer of 2019, the AICPA issued a new standard that is effective for periods ending on or after December 15, 2021. Within this standard, are changes to audit requirements, engagement acceptance procedures,  and communications related to findings.  Management responsibilities are also more explicitly defined and include, but are not limited to maintaining plan documents, following plan terms, and determining if an ERISA Section 103(a)(3)(c) audit (previously known as a limited scope audit) is permissible. Plan management will need to determine if the information is appropriately certified under 29 CFR 2520.103-8 and 29 CFR 2520.103-5. 


The EBPAQC has released a tool that plan management can utilize to help determine if an ERISA Section 103(a)(3)(c) audit is allowable for your plan:

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