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Deloitte comments on AICPA's proposal on financial statements of employee benefit plans subject to ERISA

Published on: Oct 02, 2017

Deloitte & Touche LLP comments on request for public comment from the Auditing Standards Board of the AICPA on its proposed Statement on Auditing Standards (SAS), Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA.

An excerpt from the comment letter is shown below:

We support the issuance of this proposed SAS in order to enhance audit quality specifically as it relates to “improving the communicative value and relevance of the auditor’s report” for employee benefit plans (EBPs) subject to the Employee Retirement Income Security Act of 1974 (ERISA). We also believe that this proposed SAS will provide users with additional insights and more transparency pertaining to the scope of the responsibilities of both management and the auditor as described in the new form of auditor’s report, when performing an engagement where management has imposed a limitation of the scope of the audit, as permitted by the Department of Labor’s (DOL’s) Rules and Regulations for Reporting and Disclosure under ERISA (“ERISA-permitted audit scope limitation”).

However, while D&T understands the impetus for many of the changes included in the proposed SAS we have the following overarching concerns pertaining to:

• Reporting on findings from procedures performed on specific plan provisions relating to the ERISA plan financial statements

• Inconsistencies between reporting requirements for audits of ERISA plan financial statements and existing reporting standards for other audits

• The impact of impeding ASB exposures drafts related to auditor reporting

• The effective date of the proposed SAS

Full text of the comment letter is available below.


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