PwC responds to proposal to change employee benefit plan audit reports

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Comment letter , PwC US Aug 21, 2017

We provide feedback on ASB proposal to require auditors to report on compliance with ERISA plan provisions.


A proposed standard issued by the Auditing Standards Board (ASB) would require the auditor's report for audits of employee benefit plans to address the plan's compliance with specific plan provisions. PwC's response highlights the view that the proposal would establish compliance requirements for plan administrators that do not exist under ERISA or current DOL or IRS regulations. In our view, the proposal would fundamentally change the nature of an ERISA plan audit, by moving away from the risk-based approach that underpins financial statement audits and expanding the auditor's responsibilities to include reporting on compliance.

In our response, we express the view that the proposed standard would need significant revision before it could be effectively implemented and achieve its intended objective. We suggest questions and principles for the ASB to consider in moving forward in order to determine whether standard setting or other actions by the ASB and others may be most appropriate to respond to the DOL's concerns about the quality of ERISA plan audits.

Learn more from In depth 2017-10, Proposed changes to ERISA plan auditor reports out for comment. The ASB recently extended the comment period on the proposal through September 29, 2017.

Contact us

Heather Horn

Heather Horn

US Strategic Thought Leader, National Professional Services Group, PwC US

David Schmid

David Schmid

International Accounting Leader, National Professional Services Group, PwC US

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