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 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 to give separate consideration to employee benefit plans when proposing to add any new disclosure requirements or modify existing requirements to disclosures that are intended to apply broadly to all types of entities.

    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 in FinREC’s Comment Letter on this FASB Exposure Draft.

    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. It was intended to provide observations about difficulties encountered in practice with current plan accounting and did not suggest possible resolutions.

    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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    AICPA Testimony on Outsourcing Employee Benefit Plan Services

    Testimony 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.
    Published on September 19, 2014

    AICPA Comment Letter on Exposure Draft of a Proposed Statement of Financial Accounting Concepts

    Comment Letter 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
    Published on August 21, 2014

    EBP Testimony and Comment Letters

    Overview Following are transcripts of AICPA testimony and comment letters related to various employee benefit plan accounting, reporting, and audit issues.
    Published on August 20, 2014

    EBP Discussion Memo - Observations About Current EBP Accounting

    Comment Letters This EP discussion memorandum, provided to the FASB, identified areas in current accounting affecting employee benefit plans that are conflicting, redundant, irrelevant, or incomplete due to the specialized characteristics of plans.
    Published on April 22, 2014

    AICPA 403(b) testimony July 21 ERISA Advisory Council Working Group Hearing

    Testimony 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).
    Published on November 19, 2013

    Definition of Public Business Entity FinREC Comment-Letter

    Comment Letter AICPA Comment Letter on Exposure Draft of a Proposed Accounting Standards Update – Definition of a Public Business Entity
    Published on October 08, 2013

    EBPAQC Testimony on Missing and Lost Participants

    Testimony On August 28, 2013, James Haubrock testified on behalf of the EBPAQC on accounting and auditing issues associated with Missing and Lost Participants.
    Published on September 04, 2013

    FASB Credit Loss ED EBP Comment

    Comment Letter File Reference No. 2012-260- Proposed Accounting Standards Update, Financial Instruments – Credit Losses (Subtopic 825-15) Comment Letter
    Published on July 25, 2013

    AICPA Letter Re EBP GAPP Privacy Principle to Advisory Council

    Comment Letter AICPA Letter to the Advisory Council re EBP GAPP Privacy Principle.
    Published on September 21, 2012

    EBPAQC SAS 70 Testimony to Advisory Council

    Testimony Testimony of Susan J. Peirce, CPA, member of AICPA Employee Benefit Plan Audit Quality Center Executive Committee to the Advisory Council on September 1, 2011 on SAS 70
    Published on September 02, 2011

    EBPAQC Letter on EBP Grant to Advisory Council

    Testimony Written testimony of James E. Merklin, CPA, member of AICPA Employee Benefit Plan Expert Panel on September 1, 2011 to the Advisory Council on EBP Grant
    Published on September 02, 2011

    DOL Response to AICPA Request for Delay in Form 5500 Filing Deadline

    Rules and Regulations The DOL responded to a letter from the AICPA asking for an automatic two-month extension for filing 2009 Forms 5500/5500-SF.
    Published on October 13, 2010

    Testimony of Michele Weldon September 16 2009.pdf

    Testimony 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.
    Published on July 01, 2010

    Testimony of Marilee P Lau July 15 2008.pdf

    Testimony 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.
    Published on July 01, 2010

    Statement of Alice A Wunderlich September 22 2004.pdf

    Testimony 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.
    Published on July 01, 2010

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