Reference / Certification

Who certifies the investments, and what that certification covers

A certification is the difference between an audit that tests your investment balances and one that does not. It is also the most confusing artifact in the whole engagement, and the one nobody documents.

The entity that signs it is frequently not the recordkeeper whose name is on your statement, but a trust company behind it. That distinction decides whether the certification is valid at all.

Maintained by the audit team at Ledgerline. Vendor neutral by policy: we never rank or recommend ourselves here.

What the rule actually says

Only a regulated institution may certify

The certification has to come from a bank, a similar institution, or an insurance carrier that is regulated, supervised and subject to periodic examination by a state or federal agency. A recordkeeper that is none of those cannot certify, though it usually holds the assets at a trust company that can.

The ERISA 103(a)(3)(C) audit, explained from the statute and SAS 136

It buys a narrower audit, not a cheaper one by default

With a valid certification the auditor may omit testing of the certified investment information. Everything else, contributions, distributions, loans, participant data, is tested exactly as it would be otherwise. The saving is real but it is confined to one area.

Partial certification is the expensive trap

A certification that covers some assets and not others leaves the uncertified ones to be audited in full. A single self-directed brokerage window or a legacy annuity contract outside the certified statement can turn an engagement quoted as limited scope into a much larger one.

It must be signed, and it must name what it covers

An unsigned certification, or one that does not identify the statement it attaches to, is not a certification. Check that the document names the plan, the period and the specific investment information, before the audit starts rather than during it.

Where every recordkeeper stands

Last reviewed September 2026

Three things decide how the certification affects your audit: whether it arrives without asking, which regulated entity signs it, and what it covers. Almost nobody publishes the last two, which is why an auditor's first week is so often spent finding out.

RecordkeeperArrives automaticallyCertifying entityWhat it coversRelease windowPublished
Guideline1 of 4
Vestwell3 of 4
Human Interest0 of 4
Betterment at Work0 of 4
ADP0 of 4
Paychex0 of 4
Empower0 of 4
Fidelity3 of 4
Principal0 of 4
Voya0 of 4
Vanguard0 of 4
T. Rowe Price0 of 4
Transamerica0 of 4
Ascensus0 of 4
Employee Fiduciary0 of 4
ForUsAll0 of 4
401GO0 of 4
Ubiquity0 of 4
Published by the recordkeeperNot published. We have asked.7 of 72 confirmed

Recordkeeper by recordkeeper

A dot is not an answer, so here is every row in full. If you work at one of these recordkeepers and a row is wrong or missing, tell us and it goes in.

Bundled recordkeeper · now part of Gusto Retirement
Arrives automaticallyNot published. We have asked.
Certifying entityNot published. We have asked.
What it coversNot published. We have asked.
Release windowAudit packages are typically available to auditors between March 31 and April 30.Published by Guideline · read 2026-09-11
Bundled recordkeeper
Arrives automaticallyRequested rather than automatic. Vestwell Trust Company can prepare a certified annual trust statement for the auditor, which the auditor needs in order to issue its report.Published by Vestwell · read 2026-09-11
Certifying entityVestwell Trust Company, a Vestwell subsidiary, rather than Vestwell itself.Published by Vestwell · read 2026-09-11
What it coversNot published. We have asked.
Release windowNo release window is published. A $500 late fee applies if Vestwell is not provided with a completed auditor's report by October 10, so the deadline runs the other way from most: it is about returning the finished report to them.Published by Vestwell · read 2026-09-11
Institutional recordkeeper · Fidelity Workplace Investing
Arrives automaticallyYes, when Fidelity Management Trust Company is trustee (or custodian for 403(b) plans) and Fidelity Workplace Services is the recordkeeper"If FMTC served as the trustee of a qualified retirement plan, or the custodian for a 403(b) plan, and the plan assets were recordkept by Fidelity Workplace Services, FMTC will issue a Trustee or Custodian Certification Statement." The standard PYES Reports package "includes the following: ... Trustee Certification Statement, or Custodian Certification Statement (for 403(b) Plans)"Auditor's Guide (2025 plan year), pp. 22, 24 · read 2026-10-01
Certifying entityFidelity Management Trust Company: "a Massachusetts-chartered trust company regulated, supervised and subject to periodic examinations by a state agency." "it is signed by an authorized signer on behalf of FMTC."Auditor's Guide (2025 plan year), p. 22 · read 2026-10-01
What it covers"The FMTC certification statement verifies both the accuracy and completeness of the contents of the Plan Year End Summary Reports (PYES) for the period FMTC was trustee (or custodian for 403(b) plans)." The certified reports are the Summary of Net Trust Assets / Summary of Net Assets for 403(b) plans, Summary of Plan Operations, 5500 Worksheet, Brokeragelink Asset Detail Report and Year-End Trial Balance. Loans: "Yes, participant loans reported on the Trial Balance, Summary of Plan Operations, Summary of Net Trust Assets and 5500 Worksheet are covered by the certification." Brokerage: "Yes, the FMTC certification letter does certify the self-directed brokerage accounts."Caveat: "FMTC may or may not be the custodian of the assets for a type of plan investment option depending on the investment and arrangement" (the guide points to its Section 6.1.28 for a breakdown by investment type).Auditor's Guide (2025 plan year), pp. 22, 23, 24 · read 2026-10-01
Release windowNot published. We have asked.
Nothing confirmed yet
15 recordkeepers

We have asked each of these and none of them publishes any of the rows on this page. They are listed rather than omitted because an empty row is a fact about the industry, and because somebody who works at one of them should be able to find their own name here.

Human InterestBetterment at WorkADPPaychexEmpowerPrincipalVoyaVanguardT. Rowe PriceTransamericaAscensusEmployee FiduciaryForUsAll401GOUbiquity

Questions people ask about this

What is a 401(k) audit certification?

A signed statement from a qualified institution confirming that the investment information it holds for the plan is complete and accurate. With one, the auditor may skip testing those investment balances, which is what the regulations call a 103(a)(3)(C) audit. It is the single biggest lever on what an audit costs.

Who is allowed to certify plan investments?

Only a bank, a similar institution, or an insurance carrier that is regulated and supervised and subject to periodic examination by a state or federal agency. A recordkeeper that is none of those cannot certify, though it very often holds assets at a trust company that can. If you are unsure which entity is doing the certifying, that is the right question to ask.

What does a certification not cover?

Only the investment information it names. Contributions, distributions, loans, participant data and everything else are tested in full either way. A certification that covers some assets but not others leaves the uncertified ones to be audited normally, which is how an engagement quoted as limited scope turns into a much larger one.