She provided testimony on behalf of The American Society of Pension Professionals and Actuaries (ASPPA) and the National Tax Sheltered Accounts Association (NTSAA). Ms. Cook�s goal was to provide the practical insights gleaned from direct interactions with plan sponsors (�boots on the ground�) regarding what the plan sponsors are experiencing with respect to the disconnect between the ERISA regulations, and the absence of a centralized trust in 403(b) plans, in a manner that is consistent with the requirements of both the Code and ERISA. She noted that in the absence of a centralized trust, compliance with Form 5500 reporting and audit requirements is extremely difficult because there is no comprehensive starting balance to use as the beginning point of an annual audit.