In separate standards, the AICPA Auditing Standards Board (ASB) addressed ERISA plan financial statements and rules for other information in annual reports.
The ASB issued Statement on Auditing Standards (SAS) No. 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, and SAS No. 137, The Auditor's Responsibilities Relating to Other Information Included in Annual Reports.
SAS No. 136 creates new reporting requirements and performance requirements for audits of ERISA financial statements, among other changes.
The new ERISA audit reporting standard changes the form and content of the auditor's report when management elects to exclude from the audit certain investment information held and certified by a qualified institution, as permitted by ERISA. This format will apply to engagements formerly known as "limited-scope" audits and now are called "ERISA Section 103(a)(3)(C)" audits.
The SAS takes effect for audits of ERISA plan financial statements for periods ending on or after Dec. 15, 2020, and early implementation is not permitted. SAS No. 136 applies only to audits of employee benefit plans that are subject to ERISA.
SAS No. 137 provides transparency related to the auditor's responsibility for information other than the audited financial statements and the auditor's report thereon included in an annual report when the auditor has obtained all the other information at the date of the auditor's report on the financial statements.
SAS No. 137 takes effect for audits of financial statements for periods ending on or after Dec. 15, 2020, and early implementation is not permitted.