EBP Testimony and Comment Letters

EBP Testimony and Comment Letters 

Following are transcripts of AICPA testimony and comment letters related to various employee benefit plan accounting, reporting, and audit issues.

AICPA Comment Letter on Proposed Revisions to the Form 5500 and Related Instructions
On November 23, 2016, a joint task force of the AICPA Employee Benefit Plan Audit Quality Center Executive Committee, the AICPA Employee Benefit Plan Expert Panel, and the AICPA Employee Benefit Plan Tax Technical Resource Panel issued a comment letter in response to the Proposed Revision of Annual Information Return/Reports (RIN 1210–AB63) issued in the July 21, 2016 Federal Register.

 

AICPA Comment Letter on Proposed Revisions to the DOL Reporting Regulations to Implement Notice of Proposed Forms Revisions
On November 23, 2016, a joint task force of the AICPA Employee Benefit Plan Audit Quality Center Executive Committee, the AICPA Employee Benefit Plan Expert Panel, and the AICPA Employee Benefit Plan Tax Technical Resource Panel issued a comment letter in response to the proposed revision to the DOL's reporting regulations needed to implement the forms revisions outlined in the Proposed Revision of Annual Information Return/Reports (RIN 1210–AB63) issued in the July 21, 2016 Federal Register.

AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standard Update, Fair Value Measurement (Topic 820) – Disclosure Framework – Changes to the Disclosure Requirements for Fair Value Measurement
March 24, 2016, the AICPA’s Employee Benefit Plan Expert Panel worked with the Financial Reporting Executive Committee (FinREC) to include a comment that employee benefit plans, including plans that file a Form 11-K with the SEC, be extended the same exemptions granted to private companies.

AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standard Update, Compensation (Topic 715): Practical Expedient for the Measurement Date of an Employer’s Defined Benefit Obligation and Plan Assets
December 15, 2014, the AICPA’s Employee Benefit Plan Expert Panel worked with the Technical Issues Committee (TIC) to include a comment that the scope of the practical expedient should be expanded to include employee benefit plans, which can also have fiscal year-ends that do not coincide with the end of the calendar month.

AICPA Testimony on Outsourcing Employee Benefit Plan Services
On August 19, 2014, the Employee Benefit Plan Audit Quality Center submitted written testimony to the ERISA Advisory Council on outsourcing employee benefit plan services.

AICPA Comment Letter on Exposure Draft of a Proposed Statement of Financial Accounting Concepts - Conceptual Framework for Financial Reporting—Chapter 8: Notes to Financial Statements
July 22, 2014, the AICPA’s Employee Benefit Plans Expert Panel worked with the Financial Reporting Executive Committee (FinREC) to include a comment that EBPs should be excluded from the scope of the conceptual framework and request that the Board establish a policy within the final SFAC.

AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standards Update – Definition of a Public Business Entity – An Amendment to the Master Glossary
October 2, 2013, The AICPA’s Employee Benefit Plans Expert Panel worked with the Financial Reporting Executive Committee (FinREC) to include a comment clarifying whether employee benefit plans that file  with  the  SEC  are  excluded  from  the definition of a Public Entity.

Employee Benefit Plan Expert Panel Discussion Memorandum on Observations About Current Employee Benefit Plan Accounting
In October 2013, the EP provided this discussion memorandum to the FASB, which identified areas in current accounting affecting employee benefit plans that are conflicting, redundant, irrelevant, or incomplete due to the specialized characteristics of plans.

EBPAQC Testimony on Missing and Lost Participants
On August 28, 2013, James Haubrock testified on behalf of the EBPAQC on accounting and auditing issues associated with Missing and Lost Participants.

AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standards Update--Financial Instruments – Credit Losses (Subtopic 825-15)
May 31, 2013, the AICPA’s Employee Benefit Plans Expert Panel worked with the Financial Reporting Executive Committee to include a comment specific to loans to participants in defined contribution pension plans in FinREC’s Comment Letter on this FASB Exposure Draft.

AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standards Update – Financial Instruments (Topic 825) – Disclosures About Liquidity Risk and Interest Rate Risk
October 8, 2012, The AICPA’s Employee Benefit Plans Expert Panel worked with the Financial Reporting Executive Committee to include comments specific to the impact on employee benefit plans in FinREC’s Comment Letter on this FASB Exposure Draft.

AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standards Update – Presentation of Financial Statements (Topic 205) – The Liquidation Basis of Accounting
October 4, 2012, The AICPA’s Employee Benefit Plans Expert Panel worked with the Financial Reporting Executive Committee to include comments specific to the impact on employee benefit plans in FinREC’s Comment Letter on this FASB Exposure Draft.

AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standards Update – Technical Corrections
AICPA’s Financial Reporting Executive Committee and Employee Benefit Plans Expert Panel’s Joint Comment Letter (December 19, 2011) on FASB Exposure Draft of a Proposed Accounting Standard Update – Technical Corrections.

AICPA Testimony on SAS 70 Reports, Fraud and Privacy Principles
On September 1, 2011, Sue Peirce with Apple Growth Partners in Akron, Ohio and a member of the EBPAQC Executive Committee, submitted written testimony on SAS No. 70 reports and the new SSAE 16 Service Organization Control Reports®.

AICPA Testimony on Fraud in Employee Benefits Plans
On September 1, 2011, James Merklin with Bober Markey Fedorovich & Company in Akron, Ohio and a member of the AICPA EBP Expert Panel, submitted written testimony on fraud in employee benefit plans.

AICPA Testimony on Generally Accepted Privacy Principles (GAPP)
On September 1, 2011, Everett Johnson, Chair of the joint AICPA/CICA Privacy Task Force, submitted a letter on Generally Accepted Privacy Principles (GAPP), and the threats or risks to personally identifiable information (PII) and how entities can use GAPP in creating and maintaining a privacy program to help protect this data.

AICPA Testimony on Current Challenges and Best Practices for ERISA Compliance for 403(b) Plans
On July 21, 2011, Robert Lavenberg, CPA, testified on behalf of the AICPA before the ERISA Advisory Council Working Group on Current Challenges and Best Practices for ERISA Compliance for 403(b).

AICPA Testimony on Employee Benefit Plan Auditing and Financial Reporting Models
On June 29, 2010, Marilee Lau and Michele Weldon testified on behalf of the AICPA before the U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans regarding employee benefit plan auditing and financial reporting models.

AICPA Testimony on Stable Value Investments
On September 16, 2009, Michele Weldon testified on behalf of the AICPA before the U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans regarding stable value investments in employee benefit plans.

AICPA Testimony on Hard-to-Value Assets
On July 15, 2008, Marilee Lau testified on behalf of the AICPA before the Working Group on Hard-to-Value Assets/Target Date Funds of the U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans regarding hard-to-value assets.

AICPA Comment Letter on the Certification of Alternative Investments in Limited Scope Audits
On April 19, 2007, the AICPA sent a letter to Bradford P. Campbell, Acting Assistant Secretary of the Employee Benefits Security Administration, U.S. Department of Labor, regarding the certification of alternative investments in a limited scope audit.

AICPA Testimony on Health and Welfare Plan Audits
On September 22, 2004, Alice Wunderlich testified on behalf of the AICPA before the Working Group on Form 5500 Health and Welfare Plan Audits of the U.S. Department of Labor Advisory Council on Employee Welfare and Pension Benefit Plans regarding health and welfare plan audits.

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