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Presenting a live 110‐minute teleconference with interactive Q&A
Employee Benefit Plan Audit Peer ReviewsEmployee Benefit Plan Audit Peer ReviewsPreparing for Risk Assessment, Control Document Inspection, and Other Peer Reviewer Concerns
1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific
TUESDAY, NOVEMBER 29, 2011
Today’s faculty features:
1pm Eastern | 12pm Central | 11am Mountain | 10am Pacific
James Smolinski Partner Baker Tilly Virchow Krause Madison WisJames Smolinski, Partner, Baker Tilly Virchow Krause, Madison, Wis.
Amanda Eaves, Partner, Null-Lairson, Houston
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E l B fit Pl A dit P Employee Benefit Plan Audit Peer Reviews Seminar
Nov. 29, 2011
Amanda Eaves, Null-Lairson@ ll l i
James Smolinski, Baker Tilly Virchow Krausej li ki@b k till [email protected]@bakertilly.com
Today’s Program
Rules Governing Benefit Plan Peer Reviews[James Smolinski]
Slide 7 – Slide 13
Recent Peer Review Experiences[Amanda Eaves]
Slide 14 – Slide 23
Documentation Issues[James Smolinski]
Slide 24 – Slide 31
Preparing For The Next Peer Review[Amanda Eaves and James Smolinski]
Slide 32 – Slide 41
RULES GOVERNING BENEFIT James Smolinski, Baker Tilly Virchow Krause
RULES GOVERNING BENEFIT PLAN PEER REVIEWS
General Comments Related To Peer Review
I. General – licensed firms have peer review requirementA. The report acceptance body (RAB) is either:p p y ( )
1. State peer review committee2. AICPA Peer Review Board’s National Peer Review
CommitteeCommitteeB. SEC registrant’s plans are not subject to peer review.C. All engagements subject to GAAS, SSARS, SSAE, GAGAS
and non SEC issuers are subject to peer reviewand non-SEC issuers are subject to peer review.II. Fiscal year-ends
Peer review is due six months after FYE; this affects plans being reviewed.
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General Comments Related To Peer Review (Cont.)( )
III. AICPA Audit Quality Center: Peer review practice monitoring task force for employee benefit plansA. Formed to focus specifically on enhancing the peer review
quality for EBP audits, as these are considered high risk engagements.
B. Recent activities 1. Revised PRP Sect. 20,700 EBP audit engagement
checklist (discussed later)2. Approved 403(b) specific questions added to the pp ( ) p q
engagements checklists3. Additional CPE trainings and webinars offered
C AICPA staff meet with DOL representives on a quarterlyC. AICPA staff meet with DOL representives on a quarterly basis.
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Applicable Guidance Related To Peer Review
I. Peer review guidanceA. AICPA Revised Interpretation 59-1C p 59
1. PR Sect. 9100: Standards for performing and reporting on peer reviews
2 Interpretations of Sect 1002. Interpretations of Sect. 1003. Systems review and engagement peer reviews
B. Peer Review Alert 11-03 - Enhanced peer review guidance for the review of employee benefit plan audit engagementsfor the review of employee benefit plan audit engagements
II. AICPA Employee Benefit Plan Audit Quality CenterA. Audit checklistB. Q&A
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Applicable Guidance Related To Peer Review (Cont.)( )
III. AICPA Revised Interpretation 59-1Consideration for selectionCA. Reasonable cross-section of the reviewed firm’s accounting
and auditing practiceB Emphasis on higher-risk practice areasB. Emphasis on higher-risk practice areas 1. Risk of engagements and types of benefit plans as part of
the selection criteria2 Limited vs full scope2. Limited vs. full scope3. Types of plans (DC, DB, H&W and 403(b) plans)C. Firm’s length of experience and number of audits performed,
C /member’s experience and CPE/specialized training
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Applicable Guidance Related To Peer Review (Cont.)( )
IV. Peer Review Alert 11-0303Unique risk associated with each type of planA. Defined contributionB Defined benefitB. Defined benefitC. Health and welfare
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Applicable Guidance Related To Peer Review (Cont.)( )
V. AICPA Employee Benefits Plan Audit Quality CenterA. History
1. 1989 DOL Office of Inspector General report finds 23% 989 O O p G p 3%of audits fail to meet professional standards.
2. 1997 – 2004: Seemed that audit quality was getting worse and spreading to the largest CPA firmsp g g
3. EBPAQC established 2004B. Resource for EBP auditors as well as clientsC Checklists for peer reviewC. Checklists for peer review
1. Tool used to evaluate engagements2. Detail review for each section of the audit
13
RECENT PEER REVIEW Amanda Eaves, Null‐Lairson
RECENT PEER REVIEW EXPERIENCES
Planning Investments Contributions Benefit payments Participant data and allocationsp Parties in interest Other
15
Planning documentationPlanning documentation1. Audit scope2. Communication with those charged with governance
Risk assessment1. Documented2 Fl th h t k2. Flow through to workpapers
Risk of material misstatement due to fraud1. Brainstorming2. Client inquiries
16
Understanding of internal controls1. Inquiries of managementq g2. Analytical procedures3. Observation and inspection
Initial auditsInitial audits1. Tests of beginning net assets2. Individual account balances
SAS 70 tSAS 70 report1. Proper use2. Documentation of review
Benefit obligation1. Calculation2. Use of actuary
17
Limited-scope audits1. Certification1. Certification2. Qualifying institution3. Comparison to the financial statements
Full-scope audit1. Tests of year-end market values 2 A h i i2. Authorization3. Realized and unrealized gains (losses)
Disclosures1. GAAP2. DOL rules and regulationsg
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Internal controls over payroll1. System understanding and documentation2 T ti2. Testing3. Deferral authorizations4. Payroll register
Testing of elective deferrals1. Participant confirmations2. Alternatives to confirmation3. Definition of compensation3 e t o o co pe sat o4. Testing of contribution5. Authorization of deferrals
Timeliness of contributionsTimeliness of contributions1. Controls2. Schedule3. Testing
19
Eligibility testing1 Participant data1. Participant data2. Timing3. When are distributions allowed?
Review and approval
Review of benefit calculations
ConfirmationsConfirmations
20
Payroll testing1 Relevant dates (birth hire etc )1. Relevant dates (birth, hire, etc.)2. Hourly rate or salary3. Hours worked
Eligibility test1. Eligibility requirements2. Related data
Investment income allocation testingg
Total net assets = Total of participant accounts
21
D t ti f k f dDocumentation of work performed1. Related parties2. Transactions
d f f l ff3. Consideration of financial statement effect Disclosure Supplemental schedules
22
Management representation1 Proper representations1. Proper representations2. Use of an attorney3. Late contributions
Staffing1. Supervision2. Training3. Experience
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DOCUMENTATION ISSUESJames Smolinski, Baker Tilly Virchow Krause
Documentation Emphasis
I. Written audit programs A. No written audit programs = “kiss of death” = modified opinionB. Important to note that “one size does not fit all”p
1. Tailor for specific types of plans> Definied contribution > Health and welfare> Health and welfare > Defined benefit2. Tailor for specific scope of plan> Limited-scope> Full-scope
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Documentation Emphasis (Cont.)
II. System of quality controlsA. How does the firm ensure quality of engagement meets q y g g
professional standards?1. Do you have an internal inspection program?2 CPE requirements2. CPE requirements3. Technical review4. AICPA quality control standards QC Sect. 10A: A firm’s
system of quality controlsystem of quality control> Lays out requirements for quality control> Independence checks> Client acceptance and re-acceptance procedures
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Documentation Emphasis (Cont.)
II. System of quality controls (Cont.)B. How does the firm measure that quality of engagement q y g g
meets professional standards?1. Are inspection results disseminated to improve quality?2 Are CPE requirements tracked and compliance2. Are CPE requirements tracked and compliance
ensured?3. Is there a second partner or reviewer who does an
independent review?independent review?
27
Documentation Emphasis (Cont.)
III. Tools and templatesA. Audit progamsB. Standardized testing templates S g p
Examples:SamplingSamplingParticipant data testingEligibilityLoansDistributionFull-scope investmentFull scope investment
28
Documentation Emphasis (Cont.)
IV. EBPAQC membership requirementsA. Designated audit partnerg pB. Partners are members of AICPAC. System of QC (CPE compliance)D Monitoring program (Inspection)D. Monitoring program (Inspection)E. Peer review report made publicF. EBPs selected for peer reviewG. Periodically file infoH. Pay dues
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Documentation Emphasis (Cont.)
V. Inspection requirementsA. Review of specific engagements p g gB. Review of CPE recordsC. Review of training program (if applicable)D Summarize and evaluate the findingsD. Summarize and evaluate the findingsE. Communicate inspection resultsF. Remediate issues as needed
30
Documentation Emphasis (Cont.)
VI. Inspection considerationsA. Internal inspections are required in the year of the firm’s p q y
peer review.B. Can be modified to avoid duplicationC Sole practitioners can satisfy the inspection requirementC. Sole practitioners can satisfy the inspection requirement
following the AICPA quality control standards in QC Sect. 10.
D Certain information is already in the EIPA’s public filesD. Certain information is already in the EIPA s public files.E. If not avaiable, you can send in your peer review report, and
the EBP AQC will coordinated publishing in the peer review public filepublic file.
31
Amanda Eaves, Null‐Lairson
PREPARING FOR THE NEXT
Amanda Eaves, Null LairsonJames Smolinski, Baker Tilly Virchow Krause
PEER REVIEW
1. Ongoing monitoringA. File reviewsB R t iB. Report reviewsC. Staff reviews
2. Identify issues as they occur
3. Modify and correct procedures as neededy p
33
1. Review prior-year comments
2. Take actionA. Change in audit programsB Ed ffB. Educate staffC. Monitor for correction
34
1. Experienced in EBP audits
2. EBPAQC member (it is a requirement if you are a member)
35
1. Plan typeA Defined contributionA. Defined contributionB. Defined benefitC. Health and welfare
36
2. Audit typeA Limited scopeA. Limited scopeB. Full scopeC. Initial audit
37
3. Engagement Hours
4. Partner
5 Manager5. Manager
38
Compile a listing of persons managing EBP audits and p g p g gtheir related experience and training
39
Practical Steps To Prepare For Peer Review
I. Review the Audit Quality Center requirements and checklistsA. Know what the reviewers will be focusing on, so you can
prepare to answer any questions related to specific engagements selected (20,700 EBP audit engagement).
B. Alert your EBP group early on regarding the peer review process.
C. Review the AQC requirements and checklists, if they haven’t Q q , yalready been reviewed through your internal inspection process.
40
Practical Steps To Prepare for Peer Review (Cont.)( )
II. Accumulate list of plans and types of engagements
III. Document how firm addressed quality control procedures laid out in your QA document - review files for adherence to your firm’s QA proceduresy Q p
IV. Review CPE compliance for all of your EBP engagement teamsteams
V. Ensure appropriate documentation of review and adherence to QA documentto QA document
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