Fiduciary Is Fun!
(a.k.a. I heart taxes)
(a.k.a. I heart taxes)
It’s that time of year where 401k plans need to be audited if they have more than 100 participants/employees. If you are such a company, you probably have someone in HR or Finance working with your plan’s recordkeeper or custodian to assist the auditor in performance of its duties. Maybe you even think that because your plan is audited that everything with the plan, including expenses, must be ok. After all, it’s being audited.
Well, you are probably incorrect. As a CPA, I wanted to write to clarify a few items around the annual Retirement Plan Audit as many people believe it does things it doesn’t do. This whole topic is top of mind at the moment because I am working with a prospect who has its plan audited. When we discussed the fees, the CFO actually referenced the audit indicating that the auditor documented $610 in fees for the plan. It was right there on the audit report. This is for a plan with over 130 employees. Sound too good to be true? It is.
Upon further digging, we found the advisor was being paid over $20,000. The recordkeeper, an insurance company, was receiving over $35,000, and yet the auditor signed off on the fees as being $610. How in the world can there be this much of a disconnect?
It’s important to understand what the audit is intended to do. According to the American Institute of Certified Public Accountants (“AICPA”) the purpose of the audit is to gain assurance that the financial statements as a whole are free from material misrepresentations. Moreover, in a Limited Scope Audit, which is almost all audits, the auditor does not audit certified investment information from an insurance company, bank, or trust company. It is in this area where the disconnect exists.
In my example above, the insurance company certified that only $610 were actual administrative expenses charged to the plan despite the fact that the plan had paid over $55,000 in additional fees! However, because the insurance company certified $610, the auditor put down $610 on the audit report and my CFO thought those were the expenses. Apparently, the auditor did not consider the extra $55,000 material to the financial statements and/or simply relied on the insurance company’s representation that $610 is all they needed to be concerned about.
Regardless of what the auditor was thinking, the above result is not good! $55,000 in fees IS MATERIAL. It may not be material to the financial statements themselves, but it is material to the employees in the plan who are saving for retirement. I’m not going to say if such a fee is prima facia excessive, that all depends upon what the employer is getting for those fees. What I am saying is that everyone should at least know what those fees are for so the right questions can be asked.
If you are an employer subject to a 401k plan audit, you may have a great auditor. However, a good auditor alone is not sufficient to provide assurance that your fees are reasonable and that you are getting appropriate services. For those answers, you need to speak with a retirement plan expert, like me.
Please give me a call. I would love to visit with you.
Pete Welsh a/k/a 401Guy
Here is what would seem like a simple question – What kind of college graduates do CPA firms hire? When I came out of college the answer was pretty simple – accounting graduates. Duh. Well, according to a new report (“Trends”) from the American Institute of Certified Public Accounts (“AICPA”), 31% of the new graduates in 2018 that public accounting firms hired were non-accounting majors. Almost 1 out of every 3 new hires was not an “accountant.” Does this surprise you?
These numbers are actually causing many in the CPA profession to reevaluate things, including the actual CPA exam itself – what it should look like, who can take it, etc. As a CPA, I have found these changes to our profession interesting. CPAs have always been on the leading edge of business changes as consultants and advisors to clients. However, as Barry Melancon, CPA President of the AICPA said of the Trends Report, “Increased demand for technology skills is shifting the accounting firm hiring model.” With more and more of the accounting profession becoming automated and technology focused, the old fashioned debit and credit skills are becoming less valuable on their own.
I suppose all of this makes sense when you think about it, but what has this shift required of accounting firms and their hiring practices? It’s caused them to think differently in many areas. The traditional career paths are changing. Incentive structures are changing. Work habits of these new non-accounting graduates are different. How is your business model changing and have you considered what these changes mean to your recruitment and staffing model?
All business models change. In fact, if the CPA profession can change as fast as it is doing, I am quite sure that almost every other business is changing as I type this. Are you a leader in your organization, and are you thinking about how your next new hire could be different from your last? Do you post positions simply to fill the same role of the prior person? Or are you thinking strategically about how your business is changing and adjusting accordingly?
I would suggest that a growing business needs to constantly be considering what it will look like and need 2 to 3 steps out. Part of that analysis should include your benefits program including your retirement plan(s). This could be both your qualified plan – 401k – and non-qualified plans. Just because you haven’t done something in the past is no reason not to consider it in the future.
If you want to have a discussion around the next generation of retirement plan and planning for your organization, please give me a call. I would love to talk to you about the unexpected.
Pete Welsh a/k/a 401kGuy