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Notice to Readers

This Audit Risk Alert (alert) replaces Employee Benefit Plans Industry Developments—2017.

This alert is intended to provide auditors of employee benefit plan financial statements with an overview of recent economic, industry, regulatory, and professional developments that may affect the audits and other engagements they perform. It also can be used by plan management and plan sponsors to address areas of audit and accounting considerations.

This publication is an other auditing publication, as defined in AU-C section 200, Overall Objectives of the Independent Auditor and the Conduct of an Audit in Accordance With Generally Accepted Auditing Standards.1 Other auditing publications have no authoritative status; however, they may help the auditor understand and apply generally accepted auditing standards.

In applying the auditing guidance included in an other auditing publication, the auditor should (using professional judgment) assess the relevance and appropriateness of such guidance to the circumstances of the audit. The auditing guidance in this document has been reviewed by the AICPA Audit and Attest Standards staff and published by the AICPA and is presumed to be appropriate. This document has not been approved, disapproved, or otherwise acted on by a senior technical committee of the AICPA.

Recognition

2018 Employee Benefit Plan Audit Risk Alert Task Force
Bertha Minnihan, Task Force Chair
Mark Blackburn
Eileen Brassil
Michelle Buckley
Sandi Carrier
Greg Clark
Kriste DeAngelo
Andrea Dudek
Monique Elliott
Judy Goldberg
Josie Hammond
Chip Harris
Marilee Lau
David Leising
Kathleen McLaughlin
Stacy Meyer
Dennis Polisner
Deborah L. Smith
Beth Thompson
David Torrillo
Diane M. Walker
Diane M. Wasser
Michele M. Weldon

The AICPA gratefully acknowledges those members of the Auditing Standards Board, the AICPA Technical Issues Committee, and the AICPA Employee Benefit Plans Audit Risk Alert Task Force who helped identify the interest areas for inclusion in this alert. The AICPA also gratefully acknowledges the contributions of the Office of the Chief Accountant, the Employee Benefits Security Administration, and the U.S. Department of Labor.

AICPA Staff
Weiwei Tang
Manager
Product Management and Development—Public Accounting

Feedback

The Audit Risk Alert Employee Benefit Plans Industry Developments is published annually. As you encounter audit or industry issues that you believe warrant discussion in next year’s alert, please feel free to share them with us. Any other comments you have about the alert also would be appreciated. You may email these comments to A&APublications@aicpa.org.

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How This Alert Helps You

.01 This Audit Risk Alert (alert) helps you plan and perform your employee benefit plan audits and can also be used by plan management and plan sponsors to address audit and accounting considerations. It provides information to assist you in achieving a more robust understanding of the business, economic, and regulatory environments in which your clients operate. This alert is an important tool to help you identify the significant risks that may result in the material misstatement of financial statements and delivers information about emerging practice issues and current accounting, auditing, reporting, and regulatory developments. For developing issues that may have a significant effect on the employee benefit plan industry in the near future, the "On the Horizon" section provides information on these topics.

.02 It is essential that the auditor understand the meaning of audit risk and the interaction of audit risk with the objective of obtaining sufficient appropriate audit evidence. Auditors obtain audit evidence to draw reasonable conclusions on which to base their opinion by performing the following:

  • Risk assessment procedures
  • Further audit procedures that comprise

—  tests of controls, when required by generally accepted auditing standards (GAAS) or when the auditor has chosen to do so, and

—  substantive procedures that include tests of details and substantive analytical procedures

.03 The auditor should develop an audit plan that includes, among other things, the nature and extent of planned risk assessment procedures, as determined under AU-C section 315, Understanding the Entity and Its Environment and Assessing the Risks of Material Misstatement.1 AU-C section 315 defines risk assessment procedures as the audit procedures performed to obtain an understanding of the entity and its environment, including the entity’s internal control, to identify and assess the risks of material misstatement, whether due to fraud or error, at the financial statement and relevant assertion levels. As part of obtaining the required understanding of the entity and its environment, in accordance with paragraph .12 of AU-C section 315, the auditor should obtain an understanding of the relevant industry, regulatory, and other external factors, including the applicable financial reporting framework. This alert assists the auditor with this aspect of the risk assessment procedures and further expands the auditor’s understanding of other important considerations relevant to the audit.

Economic and Industry Developments

The Current Economy

General Discussion

.04 Recognizing that economic conditions and other external factors relevant to an entity and its environment constantly change, it is important for auditors to evaluate whether changes have occurred since the previous audit that may affect their reliance on information obtained from their previous experience with the entity. These changes may affect the risks and risk assessment procedures applicable to the current year’s audit.

.05 When planning an audit, auditors need to understand the economic conditions facing the industry in which an entity operates, as well as the effects of these conditions on the entity itself. These external factors—such as interest rates, availability of credit, consumer confidence, overall economic expansion or contraction, inflation, and labor market conditions—are likely to have an effect on an entity’s business and, therefore, its financial statements. Regulatory changes and updates to accounting, auditing, and reporting standards can also have an effect on the current year’s audit. Considering the effects of external forces on an entity is part of obtaining an understanding of the entity and its environment.

.06 The year 2017 was marked by steadily increasing employment rates, lackluster wage growth, and an increase in long-term interest rates. The U.S. stock market continued to hit record high levels despite a number of hurricanes, wildfires, and other natural catastrophes that made 2017 the most expensive year on record for natural disasters.

.07 At its December 2017 meeting, the Federal Reserve increased the target federal funds rate by 25 basis points, to a range of 1.25 percent to 1.50 percent, as it continues to scale back post-economic-crisis incentives amid strong growth and less unemployment. The challenge for the U.S. economy for 2018 will be continuous growth at a sustainable pace while deterring higher-than-normal inflation.

Employee Benefit Plan Considerations

.08 Part of obtaining an understanding of the entity and its environment is considering how external forces affect an employee benefit plan. This consideration allows the auditor to plan and perform the audit to address risks identified. Gaining a new perspective with each audit is helpful because economic conditions and trends in the employee benefit plan industry may create additional risks of material misstatement that did not previously exist or did not have a material effect on the audit of the employee benefit plan in prior years.

.09 The following are trends or events that have occurred over the past few years that may be important for auditors to consider when gaining an understanding of the industry, in light of the current economic environment:

  • Increases in company mergers, spin-offs, and acquisitions causing significant plan transfer activity and potential missing participant data
  • Continued downsizing of companies leading to a full or partial plan termination
  • Increases in auto enrollment and escalation features in defined contribution (DC) plans adding to changes in operational risks as well as potential missing participant data
  • Increases in hardship withdrawals and participant loans as a result of economic conditions in areas affected by the natural disasters
  • Release of the Society of Actuaries (SOA) "Mortality Improvement Scale MP-2017," which reflects an increase in age-adjusted U.S. population mortality rates
  • Release of updated Static Mortality Table by the IRS for minimum-funding purposes
  • Increases in lump-sum buy-out windows offered to terminated vested participants or other de-risking strategies to reduce obligations for defined benefit plans
  • Increase in legal action and settlements involving the appropriateness of investment offerings and fees, resulting in fiduciary and nonexempt transaction considerations
  • Changes to plan investment options and fee arrangements, as plan sponsors consider the current economic conditions and best practices in plan oversight
  • Significant modifications to the determination letter program for individually designed plans, as well as changes to pre-approved plans by the IRS that combine the master and prototype and volume submitter programs into one program
  • Participants working beyond their normal retirement date, requiring plan sponsors to monitor minimum-required distribution rules
  • Increases in participant data breaches for benefit plans relating to cybersecurity risk
  • Increases in employer wellness programs as preventative care to compliment traditional health and welfare (H&W) benefits