Once a company meets the IRS requirements that trigger a 401k plan audit, there are a few things that a company will need to do to prepare. After your company identifies an auditor, there are several standard items they will request including bank statements and reconciliations, payroll reports, and meeting minutes. During the audit, your auditor will request a sample of plan participants to view their employee files and compensation support. As part of the process, your auditor will need to know if any new amendments were made to the plan during the past year.
As the plan sponsor, the company will have the fiduciary responsibility to act in the best interest of the 401k plan participants. Fiduciary responsibilities include ensuring the plan operates in accordance with the plan agreements, making sure plan expenses are reasonable, and holding regular meetings which cover topics such as investment performance.
As part of the 401k plan audit requirements, a number of items must be reviewed. The following is a checklist to help ensure your auditor has the information needed to complete a 401k plan audit on behalf of your company. While not an all-inclusive checklist, by compiling the related documents below it will help to ensure a smooth audit process.
401k Plan Audit Checklist
- Plan documents:
▢ Adoption agreement and plan document
▢ IRS determination or opinion letter
▢ Summary plan description
▢ Amendments (if any)
▢ Agreements with custodians or third-party administrators
▢ Meeting minutes (investment committee and board of director)
▢ Evidence of Fidelity Bond coverage
- Annual Reporting Packages:
▢ Plan level reports summarizing activity for the year
▢ Schedule of investments by fund
▢ Schedules of contributions, rollovers, loans, hardship withdrawals, COVID withdrawals and distributions by participant
▢ Certification letter
▢ Internal control reports (SOC reports)
▢ Non-discrimination testing results
- Human Resources will be responsible for providing documentation for any employees selected for testing included:
▢ Evidence of birth, hire and termination dates (if applicable)
▢ Authorized pay rates
▢ Year-end payroll reports
▢ Employee enrollment or deferral change forms, withdrawal request forms and/or loan request forms.
- Financial statements:
▢ Statement of net assets available for benefit (two years)
▢ Statement of changes in net assets available for benefits (one year)
▢ Schedule of assets held at the end of the year and other supplemental forms (as needed)
▢ Completed Form 5500
If you need help completing your company’s 401k plan audit requirements, please contact an Untracht Early assurance advisor.