Reference / Requests

What an auditor asks for, and who actually has it

17 recurring requests, held by four different organisations. Most of the delay in a first audit is not difficulty, it is requests sent to the wrong one of the four.

Nothing here is specific to your plan, which is the point: this is the same list every year, so it can be gathered before an auditor is even engaged.

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

Four organisations, not one

Your recordkeeper cannot produce your payroll registers and your payroll provider cannot produce your plan document. Knowing which is which is most of the first week.

7Recordkeeper
1Payroll provider
6Third party administrator
3You

The requests

4 of them are the ones that arrive late. Ask for those in week one.
Signed plan document and every amendment
Third party administrator
The audit tests whether the plan was run the way the document says. Without the signed document there is nothing to test against, and an unsigned or missing amendment is itself a finding.
Adoption agreement, and the latest restatement
Third party administrator
This is where the elective choices live: eligibility, entry dates, the match formula, vesting. Nearly every operational finding traces back to a plan that stopped matching one of these.
IRS determination or opinion letter
Third party administrator
Evidence the document's form is approved. A pre-approved plan relies on the provider's opinion letter rather than its own determination letter.
Certified trust statement
Usually the slowest to arrive
Recordkeeper
The statement of assets the certification attaches to. In a 103(a)(3)(C) audit this is what lets the auditor take the investment balances as given rather than testing them.
The certification itself
Usually the slowest to arrive
Recordkeeper
A signed statement from a qualified institution that the investment information is complete and accurate. Without it, or with one that covers only part of the assets, the engagement is a full scope audit at a materially higher fee.
Participant account detail, start and end of year
Recordkeeper
Balances by participant and by source. This is what the participant-level testing samples from, and what the audit reconciles to the trust statement.
Contribution remittance detail
Recordkeeper
Every deposit, with the date it reached the plan. Tested against payroll to find late deposits, which is the single most common finding in a first audit.
Payroll registers for the whole plan year
Payroll provider
The other half of the late deposit test, and the source for compensation testing. The auditor needs the date each amount was withheld, not just the pay date.
Census and eligibility data
Usually the slowest to arrive
You
Hire dates, termination dates, hours and compensation for everyone, not just participants. Used to test that people who became eligible were actually enrolled.
Distribution detail
Recordkeeper
Payments out of the plan, tested for approval, correct vesting and correct tax reporting. Expect the auditor to ask for the underlying election forms on a sample.
Participant loan detail and amortisation schedules
Recordkeeper
Tested for the loan maximum, the repayment term and whether repayments actually happened. A missed repayment can become a deemed distribution.
Forfeiture account activity
Third party administrator
What went into forfeitures and what it was used for. Forfeitures left unused for years are a recurring finding and are now drawing regulatory attention.
SOC 1 report, and a bridge letter if the period is short
Usually the slowest to arrive
Recordkeeper
How the auditor gets comfort over controls at the recordkeeper. If the report period ends before the plan year does, a bridge letter covers the gap.
Compliance testing results
Third party administrator
ADP and ACP, top heavy, the 415 limits and the 402(g) deferral limit. The auditor checks the tests were run, passed, and that any correction actually happened.
Draft Form 5500
Third party administrator
The audited financial statements attach to it, so the numbers have to agree. Send the draft early: disagreements between the 5500 and the financials are found late and cost days.
Fidelity bond
You
ERISA requires anyone handling plan funds to be bonded for at least ten per cent of the funds they handle. Bonds get set when the plan starts and rarely resized, so a short bond is among the most common findings there is.
Investment committee minutes and the investment policy
You
Evidence that somebody is actually monitoring the investment lineup. Often the request that surprises a first-time sponsor most, because the answer is frequently that no minutes exist.

The translation half of this table is still open

Knowing that your auditor wants contribution remittance detail does not tell you that your recordkeeper calls that report something else entirely, under a menu you have never opened. That mapping, 18 recordkeepers against these 17 requests, is what this page is eventually for.

We are not going to guess at it. Report names change, they differ by platform tier, and a wrong one sends somebody hunting through a portal for an afternoon. It gets filled in from recordkeepers telling us and from real engagements, and every row will say which. Tell us what yours are called and they go in.

Questions people ask about this

What documents does a 401(k) audit ask for?

Roughly seventeen recurring items, held by four different organisations: the plan document and testing from your third party administrator, trust and participant detail from your recordkeeper, payroll registers from your payroll provider, and the census, bond and committee records from you. Most first-year delay comes from sending requests to the wrong one of the four.

What takes longest to get?

The certification and the certified trust statement, the SOC 1 report, and the census. The first two sit behind a recordkeeper's own release calendar, which you do not control, and the census usually has to be assembled rather than exported. Request all three the week the engagement is signed.

Why does the auditor want payroll registers when the recordkeeper has the contributions?

Because the test compares them. The recordkeeper knows when money arrived; only payroll knows when it was withheld. The gap between those two dates is what determines whether a deposit was late, and a late deposit is the most common finding in a first audit.