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What is SAS 136 and how does it affect your Retirement Plan Audit?

The American Institute of CPA’s Auditing Standards Board (AICPA) published Statement on Auditing Standards (SAS) No. 136 that will be effective for audits of ERISA plan financial statements for periods ending on or after December 15, 2021.

This is a new audit standard to enhance audit requirements and deficiencies in limited-scope audits.

Possible changes for plan sponsors are:

  • Your audit engagement acceptance will most likely be updated to include management acknowledgements and representations of their understanding and responsibility for the plan, its administration, documents with amendments and disclosures.
  • For plans that were eligible for ERISA Section 103(a)(3)(C) audit “limited-scope audit”, now will need to confirm they are eligible for the exception and make a representation in writing.

There was an article in PLANSPONSOR dated October 18th that explains the reason for the new audit standard and what to expect going forward.  Most of the burden will fall on the auditor but plan sponsors should be prepared to answer questions about what they as a plan sponsor are doing with respect to plan management.

First State Trust Company (FSTC) provides annual certified statements for all plans and that is one of the requirements for plans that are eligible for a limited-scope audit.  With the plan sponsor’s consent FSTC will work directly with your auditors to provide any information that they require to complete the audit that we have access to.

First State Trust Company is a directed trustee, custodian and paying agent for traditional Defined Benefit Plans, Defined Contribution Plans as well as Multiple Employer Plans.

For more information, please feel free to contact me:
David Draper, Managing Director & COO
Phone: (302) 573-5808 / Email:

The posts expressed are views of FSTC and are not intended as advice or recommendations. For informational purposes only.  FSTC does not offer tax or legal advice, professional counsel should be sought for tax or legal advice.

David Draper
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