First, let’s clarify the difference between the three audit types.
In July 2019, the AICPA Auditing Standards Board (ASB) issued a new auditing standard that updates the performance and reporting requirements of ERISA plans. As a result, limited-scope audits are now referred to as ERISA section 103(a)(3)(C) audits (or ERISA 103 audit for short.)
An ERISA 103(a)(3)(c) audit (formerly known as a limited scope audit) does not require the auditor to test investment information. The custodian holding the assets attests to the accuracy and completeness of this information, eliminating the need for an auditor to test it.
A full scope audit must be performed if certification cannot be obtained from a qualified institution (bank, trust company, or insurance company). If you need assistance in determining whether you will need an ERISA 103(a)(3)(c) audit or full scope audit, please call our office.