Professional Accounting Blog

    Accounting For Your Prosperity

    Brian Dunfee

    Brian Dunfee is a Senior Manager in the Benefit Plan Group. With 12+ years of experience, Brian strongly understands many types of employee benefit plans.

    Recent Posts

    Benefit Plan Compliance Alert 2019: Are You Ready?

    Posted by Brian Dunfee on Feb 25, 2019 9:50:25 AM

    Topics: Benefit Plan Advising & Auditing

    Inherent in any successful benefits strategy is awareness and action regarding the regulatory environment surrounding your employer-sponsored plans.  Below, we have compiled a few reminders of upcoming regulatory deadlines:

    All deadlines below assume a calendar plan year-end:             

    First Quarter 2019 (and beyond):  Helpful Hints to Navigate

    February 14: The Department of Labor’s regulations on fee disclosure include a requirement to issue certain disclosures to participants/beneficiaries by 45 days after each quarter-end for participant-directed DC plans.

        o This disclosure is required for all participants with an                    account balance as of the end of the quarter.

        o It is likely that your TPA handles this quarterly disclosure for you.  However, this is a good opportunity to                 monitor the process in place at your TPA to ensure that these disclosures are being mailed out to participants         in a timely manner.

    Note: The DOL is continuing their scrutiny of compliance with these regulations and your fiduciary responsibility does not stop at assigning this task to your TPA, so be sure to maintain due diligence with this process! 

    Read More

    Cybersecurity: Employee Benefit Plan Edition

    Posted by Brian Dunfee on May 22, 2018 8:44:00 AM

    Topics: Accounting & Auditing, Benefit Plan Advising & Auditing

    The threat of cybersecurity is nothing new these days.  However, the threat continues to promulgate itself into more and more aspects of our daily life.  From GPS systems to automobile computer systems to social media platforms, cybersecurity threats are continuing to evolve and will continue to inflict harm on the unprepared.  And, employee benefit plans are no exception.

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    DOL Audit Risk: Missing Participants in Defined Benefit Plans

    Posted by Brian Dunfee on Feb 15, 2018 9:16:00 AM

    Topics: Accounting & Auditing, Benefit Plan Advising & Auditing

    The challenge of locating missing participants for benefits due to them under a qualified retirement plan is nothing new.  However, an apparent new focus by auditors with the U.S. Department of Labor (DOL) regarding vested benefits under a defined benefit pension plan (DB) is making this challenge especially onerous and, potentially, costly.

    The DOL has recently begun seeking out for audit inquiry those plans that have filed Form 5500s indicating large numbers of terminated vested participants.  The data included on the census file may be focused on demographic and historical payroll data in order to provide for accurate benefit payment calculations.  However, as time goes on, those components of the census may not change but mailing addresses can become obsolete very quickly after termination of employment and as time progresses beyond that date.

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    IRS and DOL Audits: Are You At Risk?

    Posted by Brian Dunfee on Jun 20, 2017 9:33:39 AM

    Topics: Benefit Plan Advising & Auditing

    The American Institute of Certified Public Accountants (AICPA) recently held their annual Employee Benefit Plans Conference. The conference provided information on current initiatives of the IRS and the DOL, as well as common findings noted based on their respective examinations and reviews of qualified plans. 

    In recent years, the IRS and DOL have indicated a focus on risk-based examinations and reviews, including identifying areas in plan operations where controls could be improved. As a result of these, they noted the following areas of focus:

    Read More

    Benefit Plan Disclosures SIMPLIFIED!

    Posted by Brian Dunfee on Sep 1, 2015 9:33:55 AM

    Topics: Benefit Plan Advising & Auditing

    A Summary of Recent Standards Update (ASU 2015-12)

    On July 31, 2015, the Financial Accounting Standards Board (FASB) announced an accounting standards update (ASU 2015-12) which directly addressed some disclosures normally required as part of the Plan’s financial statements. Normally, these pronouncements add disclosure requirements. But in much-heralded and much-appreciated turn, the new update reduces some of the more cumbersome and least informative of these disclosures.

    The effective date of the ASU is for plan years starting after December 15, 2015 (so, effectively, 2016 calendar plan years). However, early adoption is permitted.

    Here is a summary of some of the most relevant provisions of ASU 2015-12:

    Read More

    Controlled Groups: What Do I Need to Know?

    Posted by Brian Dunfee on Mar 12, 2015 8:45:00 AM

    Topics: Benefit Plan Advising & Auditing

    Some of the major complexities of many qualified retirement plans result from the various subsidiaries and other entities that are part of the larger corporate parent. There are specific definitions within various regulatory provisions that need to be considered.

    What is a controlled group?

    A controlled group exists if a parent-subsidiary or brother-sister group exist: Read More

    Benefit Plan Compliance Alert 2015: Are You Ready?

    Posted by Brian Dunfee on Dec 4, 2014 12:33:18 PM

    Topics: Benefit Plan Advising & Auditing

    As 2014 approaches its end, our attention naturally turns to reflection but also to planning for the coming new year. Inherent in any successful benefit plan strategy is awareness and action regarding the regulatory environment surrounding your employer-sponsored plans. Below, we have compiled a few reminders of upcoming regulatory deadlines:

    All deadlines below assume a calendar plan year-end:

    First Quarter 2015: Helpful Hints to Navigate

    • January 31: When did you last apply for a determination letter from the IRS for your individually-designed qualified retirement plan? It may have already been 5 years! We advise that you contact your ERISA counsel and discuss what may be required of you:
    Read More

    Plan Sponsor Dilemma: Missing Participants – What Should I Do?

    Posted by Brian Dunfee on Sep 2, 2014 10:31:00 AM

    Topics: Benefit Plan Advising & Auditing

    When the decision is made to terminate a defined contribution plan subject to ERISA, an important consideration for the plan sponsor is how to locate participants in order to distribute their vested benefit under the plan. Most participants will be readily locatable using personnel records currently on file. However, in the event of unresponsive or missing participants, the fiduciary provisions of ERISA require the plan sponsor to locate these participants and ensure that their account balances are distributed. The Department of Labor recently issued Field Assistance Bulletin 2014-01 which provides assistance to fiduciaries to properly discharge their obligations to these participants. 

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    Below are some suggested steps to help fulfill these obligations. The failure to take such steps would violate ERISA’s fiduciary obligations of prudence and loyalty.

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    IRS Focusing on Benefit Plan’s Controls: Tips on Being Proactive

    Posted by Brian Dunfee on May 29, 2014 5:08:00 PM

    Topics: Benefit Plan Advising & Auditing

    The Internal Revenue Service (IRS) recently announced its focus on internal controls as the basis for determining the scope of the audit when a benefit plan is selected for audit. The IRS has indicated that they will be concentrating on the various policies and procedures that are intended to govern the plan. A few of the areas that they intend to look at are:

    • Participant loans and proper defaulting of loans that reach this status;
    • Employee contributions and their timely remittance;
    • Fees and other compensation paid to service providers and the controls surrounding approval of these monies;

    In anticipation of the investigation of these areas, some common documents that the IRS auditor will request include the following:

    Read More

    ADP/ACP Safe Harbors: Does Your Plan Really Fit Inside The Harbor?

    Posted by Brian Dunfee on Mar 4, 2014 2:09:00 PM

    Topics: Benefit Plan Advising & Auditing

    When an impending storm threatens to bear down on you, ensuring that you have a safe place to go is of paramount importance. The same is also true when the IRS comes calling on your tax-qualified retirement plans. How can you be sure that your harbor is truly a safe haven from this “storm”? In general, the following are the basic plan design elements that can be implemented to qualify your plan as fitting into the “safe harbor”:

    • Employer Matching Contribution
      • 100% of the first 3 % deferred plus 50% of the next 2% deferred;
    • Employer Non-Elective Contribution
      • 3% of compensation to each eligible non-highly compensated employee, regardless of participation, annually;
    Read More

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