ERISA Section 103(a)(3)(C) Audits

The Center has compiled tools and resources to assist members and plan clients in understanding and performing ERISA Section 103(a)(3)(C) audits.

EBPAQC tools

ERISA Section 103(a)(3)(C) audits of employee benefit plans
This primer tool provides a general description of the statutory and regulatory basis that permits the plan administrator to make the ERISA Section 103(a)(3)(C) audit election, what constitutes a proper certification from a qualified institution, management’s responsibilities, the ERISA Section 103(a)(3)(C) audit in the current environment, and the effect of the ERISA Section 103(a)(3)(C) audit election on the independent auditor’s responsibilities.

Common deficiencies in ERISA Section 103(a)(3)(C) audit certifications
This tool helps plan management understand its responsibilities for determining the acceptability of an ERISA Section 103(a)(3)(C) certification; helps auditors understand their responsibilities with respect to the certification; and helps both plan administrators and auditors identify common deficiencies in certifications. It also includes an illustration of a proper certification.

Conditions for plan management to elect an ERISA Section 103(a)(3)(C) audit
This tool is intended to assist plan management in assessing whether the conditions for electing an ERISA Section 103(a)(3)(C) audit have been met.

Documentation of the auditor’s evaluation of management’s assessment of an ERISA Section 103(a)(3)(C) audit certification
This tool is intended to assist the auditor in documenting procedures performed related to an ERISA Section 103(a)(3)(C) audit certification.

AICPA resources
AICPA Audit and Accounting Guide, Employee benefit plans, provides information about ERISA Section 103(a)(3)(C) audits, as well as guidance for planning and performing them.