1C. HR: Retirement Benefits Refresher. CAPLAW 2011 National Training Conference

Transcription

1 1C. HR: Retirement Benefits Refresher CAPLAW 2011 National Training Conference Wednesday, June 15, :15 p.m. 5 p.m. Minneapolis, MN Ms. Theresa Corona, Esq. Shareholder Leonard, Street and Dienard 150 South 5th Street, Suite 2300 Minneapolis, MN theresa.corona@leonard.com Ms. Diane Simpson, CPA, QPA, QKA, TGPC Employee Benefit Plan Manager Abdo, Eick & Meyers, LLP 11 Civic Center Plaza, Suite 300 P.O. Box 3166 Mankato, MN (direct) dsimpson@aemcpas.com Handouts: 1. Corona PowerPoint Slides 2. Simpson PowerPoint Slides 3. Exhibit Handout

2 CAPLAW Retirement Benefits Refresher Theresa E. Corona June 15, Types of Retirement Plans and Who Can Sponsor 401(k) Plan Part of a profit sharing or bonus plan Defined contribution plan with individual accounts Must meet applicable nondiscrimination and coverage requirements Under which a covered employee has the choice between cash and contributing compensation into the plan Types of Retirement Plans and Who Can Sponsor 401(k) Plan Distributions permitted only at specified events Severance from employment Death Disability Age 59 ½ Hardship Qualified military distributions (if permitted by the plan) 1

3 Types of Retirement Plans and Who Can Sponsor 401(k) Plan Income tax is deferred until amounts are distributed, unless Roth contributions Employee contribution limit of the lesser of $16,500 or 100% of compensation (on a combined basis with 403(b) contributions), total contribution limit of $49,000 in 2011 Employee contributions are nonforfeitable Types of Retirement Plans and Who Can Sponsor 401(k) Plan Plan may also provide for matching contribution and/or profit sharing/nonelective contribution Can be sponsored by For profit entity (corporation, partnership, LLC, sole proprietor) Tax-exempt entity of any type, but not by state or local government or political subdivision or agency or instrumentality of state or local government Types of Retirement Plans and Who Can Sponsor Other similar plans for smaller employers: SIMPLE SIMPLE 401(k) SEP See IRS Publication 560 Less flexible than other plans, but also simpler to administer 2

4 Types of Retirement Plans and Who Can Sponsor 403(b) Plan Eligible employee can elect to receive cash or make a contribution to the 403(b) plan Can be maintained By a tax exempt organization described in Code section 501(c)(3) For an employee (other than an employee described in clause (i)), who performs services for an educational organization described in Code section 170(b)(1)(A)(ii) Types of Retirement Plans and Who Can Sponsor 403(b) Plan By an employer which is a State, a political subdivision of a State, or an agency or instrumentality of any one or more of the foregoing Employee contributions are nonforfeitable Employee contributions to this plan (and any 401(k) plan) are limited to the lesser of $16,500 or 100% of compensation in 2011 Types of Retirement Plans and Who Can Sponsor 403(b) Plan Employer matching contributions are permitted Can be invested in custodial accounts or annuity contracts Distributions permitted only at specified events severance from employment death Disability age 59 ½ Hardship qualified military distributions 3

5 Types of Retirement Plans and Who Can Sponsor 403(b) Plan Universal availability requirement all employees must be eligible to participate if any are eligible, except for those participating in another qualifying retirement plan sponsored by the employer, nonresident aliens, and employees who normally work less than 20 hours per week Nondiscrimination rules apply If nominal employer involvement, ERISA does not apply Types of Retirement Plans and Who Can Sponsor Money Purchase Pension Plan Employer contributions required under specified formula, often % of compensation Must meet nondiscrimination and coverage tests, contribution limits of $49,000 in 2011 A defined contribution plan with individual accounts, but annuity requirements apply Can be sponsored by any type of entity (if entity has authority) Types of Retirement Plans and Who Can Sponsor 457(b) Plan Eligible deferred compensation plan maintained by a state, political subdivision of a state, or any agency or instrumentality of such entity, and any tax-exempt organization other than a governmental unit Can provide benefits for anyone providing services to the entity (i.e., including directors or independent contractors) 4

6 Types of Retirement Plans and Who Can Sponsor 457(b) Plan Contributions made to the plan for a participant cannot exceed the lesser of a dollar limit ($16,500 in 2011) or 100% of compensation, but this limit applies separately to 457(b) contributions, and they are not aggregated with 401(k) or 403(b) contributions in applying those limits During last 3 years before plan s retirement age, may be able to provide additional contributions to catch-up Types of Retirement Plans and Who Can Sponsor 457(b) Plan Governmental plans must set aside funds to pay benefits; plans maintained by other tax-exempt entities must pay benefits from general assets, subject to claims of general creditors Types of Retirement Plans and Who Can Sponsor Defined Benefit Pension Plan Contributions are made by employer sufficient to allow the plan to pay a specified benefit at retirement Subject to PBGC regulation unless exempted (e.g., government plan) Must meet applicable nondiscrimination and coverage requirements Annuity requirements apply 5

7 Types of Retirement Plans and Who Can Sponsor Defined Benefit Plans Can be maintained by any type of entity (if entity has authority) Contributions limited by deductions, but benefit accruals limited by Code ERISA or Non-ERISA? The Employee Retirement Income Security Act of 1974 ( ERISA ( ERISA ) Covers pension benefit plans established or maintained by an employer or by an employee organization, or by both, and such plan, fund, or program provides retirement income to employees, or results in a deferral of income by employees for periods extending to the termination of covered employment or beyond ERISA or Non-ERISA? A retirement plan is not covered by ERISA if it is a governmental plan (a plan sponsored by the federal or any state government, or by any political subdivision, agency or instrumentality of the federal or state government), or a church plan ERISA preempts state laws relating to employee benefit plans, unless an exception applies (e.g., laws regulating insurance, criminal statutes) 6

8 ERISA or Non-ERISA? If a plan is covered by ERISA State laws regarding fiduciary obligations and certain state law causes of action are preempted Remedies under ERISA are limited to the benefits a person is entitled to under the plan, i.e., to put the person back into an equitable position ERISA disclosure and other requirements apply ERISA or Non-ERISA? If a plan is not subject to ERISA State laws regarding fiduciary obligations (e.g., trust laws) and other state law causes of action are not preempted Remedies under state law may include punitive or other special damages ERISA disclosure and other requirements do not apply ERISA or Non-ERISA? Fiduciary Requirements ERISA Plans Fiduciary shall discharge duties solely in the interest of the participants and beneficiaries and with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent man acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims 7

9 ERISA or Non-ERISA? Fiduciary Requirements ERISA Plans Diversifying investments Operating plan in accordance with its terms ERISA section 404(c) may apply for defined contribution plan where individuals direct the investment of their accounts; intended to protect employer from individual choices regarding investments provided proper fiduciary consideration is given to portfolio of choices ERISA or Non-ERISA? Fiduciary Requirements Non-ERISA Plans Governed by state law Often borrowed from state trust law Often some deference to ERISA standard Benefit claims often decided based on state contract or employment law Forms 5500 Who has to file? ERISA covered plans Small employers, generally < 100 participants can file simpler form Various schedules required depending on size of plan; large plans must file Schedule C listing expenses paid by plan to service provider of >$5,000 Due last day of 7 th month after end of plan year, unless extension applies DFVC Program available for late filers who have not received notice from DOL Pay capped penalty; file 5500s late 8

10 Fee Disclosure Regulations apply only to ERISA covered plans, but... Three prongs: Reporting of fees/expenses on Form 5500 Schedule C Service providers required to disclose fees to plans (you may finally find all your 403(b) arrangements!) Plans required to disclose fees/expenses to participants Fee Disclosure ERISA fiduciary obligation to review/assess fees paid from plan assets to determine reasonableness Ask for more from your vendors RFP vs. evaluating current vendor? Procedure, procedure, document! EPCRS Employee Plans Compliance Resolution System Authorized in statute Rev. Proc is current program Consists of three types of corrections Self correction program (SCP) Voluntary correction program with Service approval (VCP) Audit closing agreement program (Audit CAP) Generally requires correction of all tax years, not just open years 9

11 EPCRS SCP eligibility Established compliance practices Insignificant operational failures, or for 403(b) or qualified plan with a determination letter; significant operational failures if corrected by end of 2 nd year after failure Correction by plan amendment only for listed items; determination letter request might be required No fee Document your corrections and keep! EPCRS VCP eligibility Correction of operational failures, including significant failures Correction by plan amendment; determination letter application may be required Fee required Streamlined submissions for certain common failures/corrections Generally, IRS does not audit failures brought in under VCP program EPCRS Most common 401(k) correction principles largely well established Still some uncertainty with Roth 401(k) contributions List of operational corrections available for 401(k)plans under EPCRS is very broad 10

12 EPCRS 403(b) determination letter/epcrs update guidance on the way (?) For now, follow current EPCRS guidance Employer fails to offer all employees the option to make contributions Plan sponsored by ineligible employer Employer formula not followed; contribution limits exceeded Permitting loans when annuity contract allows, but not plan document EPCRS IRS website states that some 403(b) errors are ineligible for EPCRS correction Written plan did not satisfy legal requirements under 403(b) (incl. regs) or written plan was not adopted by 12/31/09 Plan failed to operate according to written terms But, IRS official says this will be added in upcoming guidance Can still correct operational violations described in current guidance Terminations/Partial Terminations Reduce employer contributions Resolution to do so before allocation conditions are satisfied If safe harbor, may need advance notice Layoff(s) can trigger partial termination of 401(k) plan Generally, if lose 20% of workforce over 12 month period Sometimes look at longer period Can exclude those who were not involuntarily terminated, or who were terminated for gross misconduct 11

13 Terminations/Partial Terminations Terminating a 401(k) plan Corporate action to terminate Fully vest participants No contributions to any other 401(k) plan for 12 months Distribute all assets to participants within 12 months Bring plan document up to date with changes in law File final form 5500 Request determination letter (?) Terminations/Partial Terminations Terminating a 403(b) plan Corporate action to terminate Fully vest participants No contributions to any other 403(b) plan for 12 months Distribute all assets to participants (including by delivery of fully paid individual annuity contract for 403(b)) within 12 months File final form 5500 Request determination letter (?) if permitted under upcoming guidance Terminations/Partial Terminations Terminate 403(b) plan Many annuity providers/custodians still not comfortable with terminations Unclear what to do if terms of individual contracts prohibit termination, or how to ensure compliance with loan, other provisions post-termination How do you know if all assets are distributed within 12 months? 12

14 Terminations/Partial Terminations IRS auditing plan terminations; likely to protect rollovers This means assessing penalties against employers if terminations not completed, rather than treating rollovers as ineligible Thank You Theresa E. Corona (612) , Leonard, Street and Deinard Professional Association. Leonard, Street and Deinard and the Leonard, Street and Deinard logo are registered trademarks. 13

15 Vendor Relationships, RFP Practices, Plan Operations, Internal Control and Audit Preparation Presented by Diane Simpson, CPA, QPA, QKA, TGPC Abdo, Eick & Meyers, LLP June 15, 2011 Vendor Relationships and RFP Practices Agenda What service providers might be helpful Specific information to request and understand about all service providers Specific information to request and understand about select service providers (TPAs, Asset Custodians, Auditors, ERISA attorneys, financial advisors) Request for Proposal (RFP) Process Vendor Relationships and RFP Practices What service providers might be helpful Bundled versus unbundled service providers Third Party Administrator Asset Custodian Financial Advisor Auditor ERISA Attorney

16 Vendor Relationships and RFP Practices Specific information to request and understand about ALL service providers (see Exhibit 1) Ask about their experience with retirement plans Do they have experience with 403b plans? Do they work with plans in your geographic area? Do they work with other plans that hold similar assets as your plan? Do they have experience working with plans with multiple asset vendors? Overall, how many retirement plans do they work on? Do they understand plans with your level of complexity? What is the size of their typical client ($s of growth each year, $s under management, number of plan participants)? Vendor Relationships and RFP Practices Specific information to request and understand about ALL service providers, continued Ask about their organizational makeup and financial health How many professionals do they have? What level of experience do their staff have? Do any of their staff hold credentials and if so, which credentials? Can you see their strategic plan? (review to ensure it covers services they will be performing for your plan) Can you review their company s financial statements for the past three years? How large is their organization? (Number of retirement plans they service, including breakdown between 403b, 401k, other) Vendor Relationships and RFP Practices Specific information to request and understand about ALL service providers, continued Ask for references & take the time to contact them (local contacts are best) Do they have a SAS70 service audit performed? If not, what documentation can they provide as to their processes and procedures? Ask about their process for implementing any new regulations that come out and for keeping you informed of any new regulations READ proposed service agreement ensure you know what they are doing versus what they expect you to do (usually an expectation gap exists)

17 Vendor Relationships and RFP Practices Specific information to request and understand about ALL service providers, continued Ask them for service timelines TPAs - for compliance testing and form 5500 preparation Asset custodians preparation of year end trust reports; timeliness of transaction processing Auditors can they meet the original Form 5500 filing deadline without extension? Financial advisors how soon after quarter s end can they provide investment analysis to the plan sponsor? Ask what they think they do the best Ask what they think they could improve upon at their company? What don t they do well Vendor Relationships and RFP Practices Specific information to request and understand about ALL service providers, continued Ask how frequently in the last year / three years they have changed staffing on plans of your size and in your area Ask if they intend to grow/ expand this area of their business and how much / many resources they intend to funnel into that goal Ask if they have processes in place to assist you with plan corrections and the fees you will be charged for those services Understand how and what they get paid ask them to map out a couple examples that would match your circumstances, including charges buried in the assets of the plan Vendor Relationships and RFP Practices Specific information to request and understand about ALL service providers, continued Ask about what they can do to help educate your employees and plan participants and fees for those services (are the fees included in what you are already paying them or are they likely to charge an additional fee for this service) Ask - When they are educating employees, how do they deal with diversity of knowledge within the employee population Ask if there has been any litigation against the organization and if so, the outcome Ask about their professional liability insurance that protects you against errors they may make

18 Vendor Relationships and RFP Practices Specific information to request and understand about ALL service providers, continued Ask about what processes they use in the event there is a dispute (mediation, litigation, etc) What level of access do you have to plan information? website? Daily valued reporting? What reports do they send you and how often? Is there any flexibility in the reports they can offer in case you have ideas of what you would like to see and it is different than their norm Find out the service provider s relationship with other service providers do they outsource any functions to others? And if so, do the outsourced entities have a SAS70 report and/or documented processes and procedures? Vendor Relationships and RFP Practices For asset custodians and TPAs or bundled service providers Do they have the ability to provide a DOL Limited Scope Audit Certification statement for the plan as a whole? Obtain copies for your records What support do they lend to assist with the preparation of the audited financial statements? What information do they have that supports the new fair market value disclosures? Ask about plan level reporting what reports can they offer at the plan level? Ask about their willingness to participate in information sharing agreements Vendor Relationships and RFP Practices For asset custodians and TPAs or bundled service providers, continued Compare service contract with plan document specifications what differences exist and can they be remedied? Example plan loans not allowed per plan document but allowed at the vendor If a large plan, ask about priority treatment for large plans to get trust reporting to third party independent auditors; also ask what information is provided in the auditor s package

19 Vendor Relationships and RFP Practices For TPAs or bundled service providers Ask about the software they use for Form 5500 preparation Affect on electronic filing and plan sponsor s role in electronic filing Timing of software updates each year Is the software on the list of approved software vendors for EFAST2 Ask about compliance testing and what assistance they lend with that process Vendor Relationships and RFP Practices For Financial Advisors Are they registered with the Securities Exchange Commission OR a state agency as a financial advisor? And if so, have they provided you with the appropriate disclosures? Inquire as to how the financial advisor gets paid What is their compensation on transfer of plan assets from one service provider to another? What are the basis points charged to the plan and its participants? Do they have any relationships with money managers that they recommend and if so, do they get compensated for recommending them? If there is a compensation component, how do they ensure there are no issues with a conflict of interest? Vendor Relationships and RFP Practices For Financial Advisors, continued What are you getting for your money? How often will they come out for employee education? What forms can employee education take? (payroll stuffers, webcasts, website education, on site seminars, some combination of each of these) How often will they assist with employee enrollment process? How often will they assist the investment committee with its task of monitoring plan assets? For ERISA attorney How do you know when an issue is legal in nature? (consult with your TPA and/or asset custodian first) Very specialized field recommend using an ERISA attorney versus corporate attorney

20 Vendor Relationships and RFP Practices For auditors Ensure they are a member of the AICPA Audit Quality Center: Offers auditor a link to other retirement plan auditors Offers auditor tools and resources Requires member firms to have adequate audit training in this area Requires member firms to have peer review performed by another member firm ensures peer review firm has an adequate background in employee benefit plan audits Ask if their licensing is current for all staff who will be working on your engagement Ask to see the latest peer review report Vendor Relationships and RFP Practices For auditors, continued Ensure that they are independent from the plan sponsor CAN be your regular corporate auditor CAN T audit the plan and also provide third party administrative or other plan services CAN prepare Form 5500 and audit the plan CAN prepare the audited financial statement as long as someone at the plan sponsor can review and take responsibility for the accuracy and completeness of the financial statements Vendor Relationships and RFP Practices Request for Proposal (RFP) Process Document the organization s criteria on which they are basing their decision to hire a vendor Establish your expectations before you shop for service providers Cost shouldn t be the only factor Proximity are they close enough to make site visits if you need them? Can they meet your employee/participant educational needs? Can they meet your expectations with regards to keeping you informed on new rules and regulations What investments do they offer? What reports do they provide? What assistance can they offer with year end compliance requirements? Can they help you maintain your plan document?

21 Vendor Relationships and RFP Practices Request for Proposal (RFP) Process, continued Document the organization s criteria on which they are basing their decision to hire a vendor, continued Ensure that each vendor for whom you are soliciting a bid gets the identical information about your plan and your expectations Don t be afraid to modify your expectations as you find out more about what services are and are not offered Be leery of the vendor who doesn t ask you the right questions Vendor Relationships and RFP Practices Request for Proposal (RFP) Process, continued Document the RFP process Take/keep notes along the way of who you talked to and what decisions were made Keep copies of any and all handouts provided to you by vendors Keep information on what you handed out to the vendors about your plan Even as you eliminate candidates, keep record of who and why they were eliminated from consideration Vendor Relationships and RFP Practices Request for Proposal (RFP) Process, continued YOU CANNOT ELIMINATE YOUR FIDUCIARY REPSONSIBILITY BY ASSIGNING IT TO YOUR SERVICE PROVIDERS: You are still the one who ultimately has the responsibility for accuracy of reporting You are still the one who has responsibility for compliance related matters You have the responsibility to monitor the plan s investments You must have someone on staff who understands how the plan operates and takes responsibility for it operating effectively and accurately

22 Vendor Relationships and RFP Practices Request for Proposal (RFP) Process, continued What are reasonable fees? Ensure each provider gets the same information about your needs Comparison to other providers in your area Level of services you want for your plan and your participants know what you want before you start interviewing service providers and then compare responses Vendor Relationships and RFP Practices Request for Proposal (RFP) Process, continued What are reasonable fees? Be aware of the risk of hidden fees or fees designed to fool you into thinking one provider is offering a cheaper service example plan document restatement fees Ask vendors who are submitting their proposal to prepare an example of all the fees that will be incurred in a plan year (examples based upon a set of facts such as 175 participants; 200 employees; participant loans allowed and 5 loans taken out in the plan year; 10 loans existed from previous plan years; we will need assistance with year end compliance testing, consolidating two service provider s information and preparation of Form 5500; we want you to provide quarterly enrollment support and participant education) give them a very specific scenario and then compare the responses you get back from various vendors Plan Operations, Internal Control and Audit Preparation Agenda Tips to help achieve effective internal controls Tips for effective plan operations How to successfully prepare for an audit of your retirement plan

23 Plan Operations, Internal Control and Audit Preparation Tips to help achieve effective internal controls Importance of having established internal controls: Help prevent loss due to intentional fraud and unintentional errors Help to maintain plan s qualified status by providing preventative care Have documented policies and procedures in the following areas as they relate to the plan: Payroll Human Resources Timely remittance procedures Plan document upkeep Key employee education on plan related issues (consider establishing an actual policy related to continuing education on plan related issues) Plan Operations, Internal Control and Audit Preparation Tips to help achieve effective internal controls, continued Segregation of duties over plan assets (See Exhibit 2) Authorization (signing checks, approving pay rates, approving plan amendments, approving plan eligibility) Custody of Assets (maintaining check stock, enrollment and beneficiary forms) Recording (sets up employee records, posts payroll to the general ledger, preparing transmittals to the third party administrator, calculating matching contributions) Reconciling activities (reconciles the bank account, review TPA reports, review TPA payroll transmittals) Plan Operations, Internal Control and Audit Preparation Tips to help achieve effective internal controls, continued Include specific plan-related responsibilities in documented job descriptions Ensure staff has adequate training and qualifications to perform their assigned plan functions Consider risky areas and assign more effort in establishing, maintaining and monitoring controls in the riskiest areas; less control in the less risky areas Review and familiarize yourself with typical user control considerations in SAS70 reports. Document now prior to an audit - how you ensure you have adequate controls in place (see Exhibit 3)

24 Plan Operations, Internal Control and Audit Preparation Tips to help achieve effective internal controls, continued Review reports from third party service providers. Ensure that staff who is responsible to review reports knows what he/she is looking at and what they should be looking for. Ensure that reports are reviewed each payroll and each month. Ensure that once controls, processes and procedures are established, that they are communicated to those in the organization whose job it will be to implement them Make sure that the tone from the top reflects the importance of sound processes and procedures Establish and document timely remittance procedures Plan Operations, Internal Control and Audit Preparation Tips to help achieve effective internal controls, continued Make sure employees have an outlet in case the person who isn t following policy is the person the employee is supposed to be answering to Make sure everyone knows the chain of command and who to ask questions of and report to re: internal controls See examples of selected controls for employee benefit plans (Exhibit 4) Plan Operations, Internal Control and Audit Preparation Tips for effective plan operations Have a plan in place to ensure adequate employee education Familiarize yourself with the actual plan document as opposed to relying on the summary plan description Check in periodically with auditor, TPA and asset custodian to find out what new legislation there is related to qualified plans; also new disclosure requirements for audited financial statements Consider limiting the number of plan vendors Develop and adhere to a fraud detection, prevention and response policy

25 Plan Operations, Internal Control and Audit Preparation Tips for effective plan operations, continued Governance Seek out Financial Advisors or community professionals who are well versed in qualified plans or financial markets for BOD members Include plan responsibilities in documentation educating board members as to what their responsibilities are Designate those in the organization with plan responsibility and then get them the initial training as well as follow up training to keep them current on the latest rules and regulations Get copy of the Department of Labor s record retention policy and mirror it for your Organization s plan records (see Exhibit 5) Plan Operations, Internal Control and Audit Preparation Tips for effective plan operations, continued Establish an investment and/or retirement plan administrative committee Who should be members of the committee? Document member responsibilities Consider member terms? Rotate membership to add new perspective? List of committee responsibilities (see Exhibit 6) Investment policy statement finding balance between too specific and not specific enough Provide employees with resource materials Pension and/or 403b Answer Books (Aspen Publishers) Understand and ensure that fidelity bond requirements are met Plan Operations, Internal Control and Audit Preparation Tips for effective plan operations, continued Compliance testing Determine who will be doing what and ensure that it is completed each year Ensure you have a complete census before performing year end compliance tests Monitoring service providers Ask participants if they have any complaints about vendors and follow up with vendors to discuss/ resolve Review contracts with service providers to ensure they are doing what they said they would do for the fee they said they would do it for Consider additional services needed from the service provider annually

26 Plan Operations, Internal Control and Audit Preparation Audit preparation Perform an internal file inspection prior to audit fieldwork dates annually Consider having audit firm discuss the audit with the board and key plan sponsor personnel prior to audit fieldwork This will help reduce expectation gap and inform everyone of their roles during the audit Take previous suggestions for your auditor and use them to improve plan operation Determine key staff who will assist with the audit (HR, payroll, board members, executive director) Plan Operations, Internal Control and Audit Preparation Audit preparation, continued Compile a list of your questions for the auditor Discuss with your service providers: Is there special access for auditors to the website? What do they offer for an auditor s package Can they provide a DOL limited scope audit certification statement Understand and familiarize executive director and board members of the difference between a clean and a clean enough auditor s report opinion Plan Operations, Internal Control and Audit Preparation Audit preparation, continued Determine who at the organization will be reviewing and accepting responsibility for the audited financial statement. If no one is qualified, consider getting someone training or consider hiring a different audit firm to prepare audited financial statements for the plan 403b plan questions to expect from your plan auditor (see Exhibit 7) 403b plan Sample Auditor Request List for Plan Information (Exhibit 8)

27 Vendor Relationships, RFP Practices, Plan Operations, Internal Control and Audit Preparation Questions? Diane s contact information Direct Dial (507) Diane.simpson@aemcpas.com Thank you for inviting me

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