Microsoft Word 2014 Audit Quality Study Final Report 52815

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1 Assessing the Quality of Employee Benefit Plan Audits U.S. Department of Labor Employee Benefits Security Administration Office of the Chief Accountant May 2015

2 Table of Contents Executive Summary ... ... 1 Background ... ... 5 6 Who Audits Employee Benefit Plans? ... Why Was the Sample of Employee Benefit Plan Audits Based on the Number of Audits Performed by the CPA Firm? ... 7 Are Deficient... 8 Too Many Employee Benefit Plan Audits Does Size of a CPA’s Employee Benefit Plan Prac tice Correlate with Audit Quality? ... 9 Are More Participants and Plan Assets at Risk With Certain Size CPA Firms? ... 10 late to the Proportion of the Firm’s How Does the Quality of a Firm’s Audits Re .. 12 Practice Devoted to EBP Audits? ... Are Practice Monitoring an d Peer Review Activities Related to Improved Audit Quality? ... ... 13 Is Membership in the AICPA’s Employee Benefit Plan Audit Quality Center 14 (EBPAQC) Related to Audit Quality? ... Does the Level of Employee Benefit Plan Specific Continuing Professional an Effect on Audit Quality? ... 16 Education by Engagement Partners Have t Areas That Resulted In More Deficiencies Were There Specific Audi Than Other Areas? ... ... 17 Did Plan Audits Comply With ERISA an d DOL Reporting Regulations? ... 18 prove Audit Quality in the Last 25 Years? ... 18 What Has Been Done to Im Conclusions ... ... 22 Recommendations ... ... 23 Appendix I: Objectives, Scope and Sample Composition ... 25 Appendix II: Audit Deficiencies, by Type of Deficiency ... 27 Appendix III: Complete Listin g of Audits with Deficiencies, by Audit Strata ... 61 ts and Peer Review Information ... 179 Appendix IV: Listing of Deficient Audi

3 Executive Summary ee Benefits Security Administration (EBSA), U.S. The Office of the Chief Accountant (OCA), Employ Department of Labor (DOL), has completed an asse ssment of the quality of audit work performed by independent qualified public accountants (IQPAs) with respect to financial statement audits of under the Employee Retirement employee benefit plans covered Income Security Act of 1974 (ERISA) for the 2011 filing year (plan year beginning in 2011). Objectives and Scope sess the level and quality of IQPAs’ audits of The primary objective of EBSA’s review was to as ERISA-covered employee benefit plans. EBSA’s assessments involved a review of the Fo rm 5500 Annual Return/Report filings and related year (plan years beginning in 2011). The Agency selected a audit reports for the 2011 filing an audits from a target popula statistically valid sample of 400 pl tion of 81,162 Form 5500 filings rt/audit opinion for 2011 in which an accountant’s repo was attached. In the 2011 Form 5500 database th ere were 81,162 filings that co ntained CPA au dit reports. Those 81,162 audits were performed by 7,330 differe nt CPA firms. Because the population of plan auditors is so diverse and heavily skewed to those CPA firms that audit a small number of plans, the sample was designed to look at the relationship between audi tor characteristics and audit quality. Historically, EBSA has found that CPAs with smaller employee benefit plan audit practices tended to have the most audit deficiencies. Ther efore, the Agency divided the population of CPAs into six st rata based on the number of pl an audits that the CPA firm determine where in the po performed with the desire to more definitively pulation deficient audit work predominated. Findings at 61% of the audits fully compli ed with professional auditing Overall, EBSA’s review found th ficiencies under professional standards. However, 39% of the standards or had only minor de audits (nearly 4 out of 10) contained major deficiencies with respect to one or more relevant GAAS requirements which would lead to rejection of a Form 5500 filing, putting $653 billion and 22.5 million plan participants and beneficiaries at risk. These figures reflect increases in the amount of plan assets and number of plan particip ants at risk compared with prior EBSA studies. Additionally, the audit review supports the following findings:  There is a clear link between the number of employee benefit plan audits performed by a CPA and the quality of the audit work performed. Analysis of the data indicates a wide disparity between those CPAs who perform the fewest plan audits and those firms that perform the largest number of plan audits. CPAs who performed the fewest number of employee benefit plan audits an nually had a 76% deficiency ra te. In contrast, the firms performing the most plan audits had a deficiency rate of only 12%.  The accounting profession’s peer review and practice monitoring efforts have not proved identification of deficient audit resulted in improved audit quality or im 1

4 engagements. ial number of CPA firms received an In 4 of the 6 audit strata, a substant es in the audit work that EBSA reviewed. acceptable peer review report, yet had deficienci  CPA firms that were members of the American Institute of Certified Public Accountants’ (AICPA) Employee Benefit Plan Audit Quality Center tended to produce audits that have CPAs in the two sma llest audit strata are fewer audit deficiencies. Overwhelmingly, most not Employee Benefit Plan Audit Quality Center members.  Training specifically targeted at audits of employee benefit plans (EBPs) may contribute to better audit work. As the level of EBP-sp ecific training increased, the percentage of deficient audits decreased.  of the audit reports failed to comply Of the 400 plan audit reports reviewed, 67 (17%) rting and disclosure requirements. with one or more of ERISA’s repo Conclusion It appears that the quality of employee benefi t plan audits has not improved since EBSA’s previous studies given an overall defici ency rate for plan audits of 39%. Additionally, EBSA concludes that:  Once again, the smaller the firm’s employee benefit plan audit practice, the greater the incidence of audit deficiencies.  Audit areas that are unique to employee be contributions, benefit nefit plans such as payments, participant data and party-in-interest/prohibited transactions, continue to lead the list of audit deficiencies. ious studies, CPAs often failed As EBSA found in its two prev t areas and, therefore, performed inadequate audit work. to consider these unique audi  CPAs failed to comply with professional standards eith er because they were not oyee benefit plan audits, or fa adequately informed about empl iled to properly utilize the technical materials that were in their possessi on. Audit partners in firms performing a greater number of plan audits tended to have a greater amount of employee benefit plan specific training. In a numbe r of instances, however, even having the proper technical guidance did not ensure that a quality audit was performed.  The Practice Monitoring Peer Review process established by the AICPA and administered by sponsoring state CPA societies does not appe ar to be an effective tool in identifying deficient plan audit work and ensuring comp liance with professional standards. While selecting an employee benefit plan audit is a required part of the peer review process (where applicable), CPAs who performed defici ent audits often received acceptable peer review reports.  Members of the AICPA’s Employee Benefit Plan Audit Quality Center (EBPAQC) tend to have fewer audits containing multiple GAAS deficiencies. Additionally, non EBPAQC of GAAS deficiencies, per audit engagement, member firms tend to have a larger number than EBPAQC members. 2

5 Recommendations makes the following elev Based upon the findings of this report, EBSA en recommendations. Enforcement 1. Revise case targeting to focus on: CPA firms with smaller employee benefit plan audit practices that audit plans a. with large amounts of plan assets, and b. CPA firms in the 25-99 plan audit strata given their high deficiency rates and the amount of plan assets ($317.1 billion) and plan participants (9.3 million) at risk from deficient audits. Work with the National Association of State Boards of Accountancy (NASBA) and the 2. AICPA to improve the investig ation and sanctioning process for those CPAs who perform significantly deficient audit work. Work with NASBA to get state boards of accountancy to accept the results of investigations perf ormed by EBSA or the AICPA’s Professional Ethics Division, in order to us e those results in disciplining CPAs (at the state licensing board level). 3. Amend ERISA to make sure the annual report ing civil penalties focus on the responsible party. Under this proposal, the Secretary of Labor would be authorized to assess all or porting civil penalty of up part of the current annual re to $1,100 per day against the accountant engaged to do an ERISA plan audit if the plan’s annual report is rejected due to a deficient audit or because the accountant failed to meet the standards for qualification to perform an ERISA plan audit. Work with the AICPA’s Peer Review staff: 4. to streamline the peer review process and make it more responsive in helping to a. improve employee benefit plan audit quality. b. to ensure that CPAs who ar e required to undergo a peer review have in fact had an acceptable peer review. c. to identify those CPAs who have not receiv ed an acceptable peer review and refer those practitioners to the applicable state licensing boards of accountancy. Regulatory/Legislative 5. Amend the ERISA definition of “qualified public accountant” to include additional requirements and qualif ications necessary to ensure th e quality of plan audits. The Secretary of Labor would be authorized to i ssue regulations concerni ng the qualification requirements. 6. Amend ERISA to repeal the limited-scope au dit exemption. This exemption prevents accountants from rendering an opinion on the plans’ financial statements for assets held 3

6 in regulated entities such as financial institut ions. When auditors have to issue a formal rful incentive to rigorously adhere to and unqualified opinion, they have a powe professional standards ensuring that their opinion can withstand scrutiny. The limited- es this incentive by removing auditors’ obligations to scope audit exemption undermin stand behind the plans’ financial statements. Amend ERISA to give the Secretary of Labor authority to establish accounting principles 7. and audit standards that would protect the integrity of employee benefit plans and the aries. Under this approach, the Secretary of benefit security of participants and benefici Labor would be authorized to establish standa rds that address financ ial reporting issues that are either unique to or on employee benefit plans. have substantial impact up Outreach Work with the NASBA to encourage state boards of accountancy to require specific 8. licensing requirements for CPAs who perform employee benefit plan audits. This would include specific training and experience in the audits of employee benefit plans. 9. Continue and expand EBSA’s outreach activities: a. Continue the Agency’s work with plan administrator organizations (e.g. ASPPA), to explain the importance of hiring competent CPAs to plan administrators and other plan fiduciaries with hiring authority. b. Use information contained in the EFAST2 database to target correspondence to: plan administrators in the 1-2 and 3- i. 5 plan strata, highlighting the high deficiency rate among plan auditors and providing information about how to select a qualified plan auditor; and ii. CPA firms in the 25-99 stratum, discussing the audit deficiencies found in the audit study and working with the firms to ensure that plan audits comply with professional standards. 10. Communicate with each of the state boards of accountancy (licensing boards) regarding the results of the study and the need to ensu re that only competen t CPAs are performing employee benefit plan audits. 11. Expand EBSA’s outreach with individual stat e societies of CPAs who have a large number of plan audits performed by CPA firms in the 1-5 plan audit stratum. For those states that do not already do so, encourage them to create employee benefit plan audit training programs. 4

7 Background dy abuses in the nation’s private pension and welfare benefit plan ERISA was enacted by Congress to reme are benefits and is administered by three separate federal agencies: system. ERISA covers pension and welf the Department of Labor (DOL), the Internal Reve nue Service (IRS) and the Pension Benefit Guaranty Corporation (PBGC). d in recognition of the need ERISA contains a number of provisions that were enacte to establish an effective mechanism to protect the interests of plan participants and beneficiar ies, and to establish an effective mechanism to detect and deter abusiv e practices. These provisions include the annual reporting of financial information and activities of employ ee benefit plans. The Secretary of Labor is principally responsible for enforcing the fiduciary and reporting and disclosure pr ovisions that are containe d in Title I of ERISA. cluded a requirement for employee benefit plans to file an annual In enacting ERISA in 1974, Congress in report of their financial condition and operations with the Department. Among other information, the plan’s 1 qualified public accountant (IQPA) annual report must include an audi t report issued by an independent stating whether the plan’s financial st atements (and other sche dules required to be included in the annual report) are presented fairly in confor mity with generally accepted accoun ting principles (GAAP). Almost all 2 must be audited annually, and the pl an administrator is responsible for plans with over 100 participants engaging an IQPA to perform the required plan audi t in accordance with generally accepted auditing standards (GAAS). Under ERISA, the De partment plays no role in setting GAAP and GAAS standards. Such utions closely related to the accounting industry - the Financial Accounting standards are set by instit 3 . ute of Certified Public Accountants (AICPA) Standards Board (FASB) and the American Instit Audited financial statements and the CPA’s report on the fairness and consistency of their presentation must thin 210 days after the clos e of the plan year. The generally be filed with the Form 5500 Annual Report wi audit requirement is intended to ensure the integrity of financial information that is incorporated in the annual reports. Section 103 of ERISA specifically requ ires that these audits be conducted pursuant to the standards established by the accounti ng and auditing profession itself in the pronouncements which define GAAP and GAAS. While ERISA’s auditing provisions ha ve worked to provide DOL and plan participants and beneficiaries with information about th e safety of plan operations, experi ence has shown that “plan” audits do not consistently meet professional standards. 1 Almost all plan audits are now performed by Certified Public Accountants (CPAs); therefore, throughout the rest of the report we will broadly refer to plan auditors as CPAs. 2 Beginning in April 2002, some small pension plans may also be required to have an annual audit pursuant to 29 CFR 2520.104-46. 3 ng standards for audits of The Public Company Accounting Oversight Board (PCAOB) is responsible for setting auditi public companies. 5

8 Objectives and Scope and quality of audit work being y was to assess whether the level The primary objective of this stud benefit plans regulated by ERISA has improved since performed by CPAs with respect to audits of employee OCA’s previous comprehensive study in 2004. EBSA’s assessments involved a revi ew of the Form 5500 Annual Return/Report filings and related audit a statistically valid sample of years beginning in 2011). OCA selected reports for the 2011 filing year (plan 400 plan audits. The workpaper reviews, performed at OCA’s office, were cond ucted during the period audit reports and suppor ting workpapers were December 2013 through September 2014. The 400 selected evaluated against AICPA’s Audit and Accounting Guide, Audits of Employee Benefit Plans (with conforming changes . as of January 1, 2012) Who Audits Employee Benefit Plans? In 2011, there were 81,162 Form 5500 filings containing CPA audit reports. The audits were performed by ber of CPA firms grouped 7,330 CPA firms. The following table summarizes the num by the number of plans audited and the total number of audits performed. The number of CPA firms decreases rapidly with an increasing number of plans audited. Fifty percent of CPA firms audit 1 or 2 plans while only 0.2 percent of CPA firms audit 750 plans or more. 2011 Form 5500 Database CPA Firms Performing Plan Audits Number of Audits Number of CPA Number of Plans Audited Firms Performed 3,684 4,891 1-2 5,773 1,519 3-5 17,747 1,603 6-24 18,910 433 25-99 15,418 77 100-749 18,423 14 750+ Total 81,162 7,330 rform employee bene fit plan audits audit less than As the following chart shows, 95% of the CPA firms that pe 100 or more benefit plans annually. sely, only 1% of the CPA firms audit 25 plans on an annual basis. Conver 6

9 Number of Audits Performed by CPA Firm by Stratum 7,330 CPA Firms 1 or 2 Audits (51%) 3 - 5 Audits (20%) 6 - 24 Audits (21%) 25 - 99 Audits (6%) 100-749 Audits (1%) 750 plus Audits (1%) Why was the Sample of Employee Benefit Plan Audits Based on the Number of Audits Performed by the CPA Firm? performing fewer employee benefit Previous assessments show that CPAs plan audits tended to have the highest proportion of deficient audit group of plan audi tors, or CPA firms, s. As shown above, there is a large that audit a small number of plans. Th e statistical sampling plan was desi gned to adequately represent the larger CPA firms as well as the smaller. The plan audi tors were grouped into six strata based on the number of plan audits that the CPA firm pe rformed in plan year 2011. The six CP A firm size strata were chosen to accurately characterize the quality of employee benefi t plan audits. Randomly sampling the six strata each subgroup of plan auditors. ensures a representative sample from 7

10 Too Many Employee Benefit Plan Audits are Deficient GAAS provides the framework for audito rs’ exercise of their professional re sponsibilities. These professional for performance of an audit engagement. The AICPA auditing standards establis h the minimum requirements creates the auditing standards for em ployee benefit plans. When auditors depart from these standards they that fact in their report. are obligated to acknowledge participants retain an plans with more than 100 ERISA Section 103(a)(3)(A) requires that employee benefit quires that the audit be IQPA to perform an audit of the plan’s financial st atements. This section re nsion plans may also be required to th GAAS. Some small employee benefit pe performed in accordance wi have an audit performed in accordance with GAAS. ing the requirements contai ned in the AICPA’s Audit OCA analyzed the work performed by plan auditors us 4 , issued and Accounting Guide, Audits of Employee Benefit Plans (with co nforming changes as of January 1, 2012) the application of professional audi ting and accounting standards that by the AICPA. This guide represents are unique to audits of employee benefit plans. fied as falling in one of the following categories: After OCA’s review, the 400 audit engagements were classi Audit Status Explanation Audit does not contain any findings Acceptable Acceptable- minor Audit is acceptable, with minor findings in certain areas of the audit GAAS deficiencies noted; however, ov erall audit quality is not adversely Unacceptable- minor affected GAAS findings noted and overall audit quality is adversely affected Unacceptable- major estimates that 61% of the audits complied with Based on these categories and sample results, EBSA ciencies. However, 39% of the audits (nearly 4 out of professional auditing standards or had only minor defi 10) contained “Unacceptable-m ajor” deficiencies with respect to one or more relevant GAAS requirements, putting $653 billion dollars and 22.5 million plan particip ants and beneficiaries at risk. This reflects an increase in the amount of plan assets and number of plan participants at risk compared with prior EBSA studies. [EBSA’s 2004 study estimated that a total of $410 billion in assets held by plans had not been properly audited.] crease in the percentage of plan atistically based studies, shows the in The chart below, based on the four st audits that do not comply with profession al audit standards ov er the past 26 years. Results of Prior Audit Quality Studies 2004 1997 1988 2014 Audit Quality Study 19% 23% Audits With GAAS Deficiencies 39% 33% The increase in non-compliant audits corresponds with the in crease in the number of limited-scope audits. o the overall audit population) has As the following chart shows, the perc entage of limited-scope audits (t increased from 48% in 2001 to 83% in 2013. 4 Applicable professional guidance for financial statement audits of plan year 2011 Form 5500 filings. 8

11 Limited-Scope Audits 2010 2002 2003 2004 2005 2006 2007 2008 2009 Filing Year 2011 2012 2013 2001 Limited- 62% 51% 67% 56% 78% 48% 79% 62% 80% 83% 81% 59% 65% Scope Audits appears that the increased number of limited- scope audits has contributed As discussed later in this report, it ve less incentive to focus on releva to declining audit quality. CPAs ha nt audit areas when they know the engagement will result in their issuance of “n o opinion” on the plan’s financial statements. Practice Correlate with Audit Quality? Does Size of a CPA’s Employee Benefit Plan Yes. The results of this audit study clearly indicate a link between the number of employee benefit plan audits performed by a CPA and the quality of the audit wo rk performed. Analysis of the data indicates a wide disparity between those CPAs who perform the fewest pl an audits and those firms that perform the largest number of plan audits. As the following chart shows, CPAs who performed only one or two employee rate at the stratum of firms benefit plan audits annu In contrast, the deficiency ally had a 76% deficiency rate. performing the most plan audits was only 12%. Major Deficiency Audit Rates by Stratum (95% Confidence Level; Statistically Significant Differences between Stratum) Lower Upper Standard Audits With Audit Strata Bound Error Reviews Bound Deficiencies 66.1% 95 75.8% 4.4% 83.4% 1-2 58.3% 95 4.8% 68.4% 77.0% 3-5 67.4% 50.9% 7.7% 80.4% 95 6-24 65 41.5% 9.7% 24.4% 61.0% 25-99 5.2% 4.9% 12.0% 25 25.4% 100-749 3.0% 25 12.0% 8.0% 37.8% 750+ 38.8% 400 Total Reviewed 45.9% 32.2% 3.5% Note: Statistics are calculated using sample weights, which account for the different amount of au dits performed by each stratum. For this reason, the population average may be different from the un-weighted sample averages. Not only did CPA firms with smaller employee benefit pl an audit practices have significantly higher overall t audit areas. As seen in deficiency rates, but their audits also had an unacceptab ly high number of deficien t stratum, 56% of the audits contained five or more deficient audit areas. the table below, for the 1-2 plan audi contained five or more Similarly, in the 3-5 plan audit stratu m, about 42% of plan audits deficiencies. Similar trends hold for the next two strata as well. In the tw o largest CPA firm audit strata, the audits that had five d unique audit situations not normally encountered in or more deficiencies (one in each stratum) presente performing a routine plan audit. 9

12 Audits Containing Five or More Deficiencies by Strata Audits With 5 or More IQPA EBP Audits # of Deficient Audits Deficiencies 53 (56%) 72 1-2 65 40 (42%) 3-5 64 37 (39%) 6-24 27 14 (22%) 25-99 1 (33%) 3 100-749 1 (4%) 3 750+ As shown in the table below, there were significant diffe rences in deficiency rates across multiple plan audit strata, with the 1-2 Plans, 3- 5 Plans, 6-24 Plans, and 25-99 Plans strata all having a significantly higher major deficiency rate than the 100-749 Pl ans and the 750+ Plans strata. Differences in Major Audit Deficiency Rate by Strata 100-749 25-99 6-24 1 & 2 750+ 3-5 Strata Plans Plans Plans Plans Plans Plans % -64 % -64 % -34 % -8 % -7 % 0 1 & 2 Plans % % -56 -56 % % -27 0 % -1 3-5 Plans 7% -26 0 % % -55 % -55 % 6-24 Plans 8% 1% % -30 -30 % 0 % 5-99 Plans 2 26% 34% 27% % 0 % 0 100-749 Plans 64% 30% 55% 56% % 0 750+ Plans 30% 56% 55% 64% 0% Significant differences across stra level are highlighted in red. ta groups at the 95% confidence Note: that performs only 1- 2 plan audits has a 64% greater For example, a plan administrator who hires a CPA chance of hiring someone whose audit contains defici encies, as opposed to the administrator hiring a CPA with an annual plan audit practice of 100+ plan audits. Certain Size CPA Firms? Plan Assets at Risk with Are More Participants and participants and plan assets impacted by audits The sample allows EBSA to estimate the number of ld by plans with audits that containing one or more GAAS deficiencies. Overall, $653 billion dollars were he As the chart below shows, 93% of the plan contained GAAS deficiencies. assets at risk were audited by CPAs dicates that 82% of the plan assets lly. Further scrutiny of the data in performing fewer than 100 audits annua 99 audit strata. strata, the 6-24 and 25- at risk were audited by CPAs in two 10

13 Plan Assets at Risk by Stratum (95% Confidence Level) Assets Held by Standard Upper Lower Plans With Deficient Audits Error Bound Bound Strata (Millions) $6,124 $27,815 $41,819 $17,794 1-2 $18,161 $19,908 $88,977 $46,686 3-5 $217,404 $101,632 $60,700 $444,807 6-24 $317,158 $854,795 $38,516 $234,512 25-99 $5,012 $7,060 $0 $17,650 100-749 $0 $24,881 $37,098 $95,264 750+ $260,840 $263,940 $1,245,938 $653,221 Total Sample Statistics are calculated using sample nt amount of audits performed by Note: weights, which account for the differe each stratum. Based on the sample results, EBSA estimates that ther ants impacted by audits e were 22.5 million particip with one or more GAAS deficiencies. 70% of participants at risk were in the 6-24 and 25-99 plan audit strata. Plan Participants Impacted by Stratum (95% Confidence Level) Participants in Plans With Upper Bound Standard Error Lower Bound Deficient Audits Audit Strata (Millions) 1.04 0.13 0.80 1.31 1-2 3-5 1.40 0.20 1.01 1.82 6.51 1.92 3.19 10.63 6-24 25-99 9.31 6.47 1.65 23.98 0.00 3.61 100-749 3.44 13.11 0.45 750+ 1.73 0.00 0.65 Total Sample 39.37 10.22 7.63 22.52 dits performed by each the different amount of au weights, which account for Statistics are calculated using sample Note: stratum. 11

14 How Does the Quality of a Firm’s Audits Relate to th e Proportion of the Firm’s Practice Devoted to EBP Audits? rformed by 232 different CPA firms. The 400 audit engagements reviewed as part of the audit study were pe the EBP practice relative to the information regarding the size of For those 232 CPA firms, EBSA gathered auditor’s complete audit practice. The chart below on across the six auditor shows that EBP specializati stratum varies widely. As the chart shows, most CPAs firms in the 1-2 and 3-5 audit strata do not specialize in EBP audits. For example, in the 1-2 strata, only 15 ered to be “specialized” % of the CPA firms are consid with respect to employee benefit pl 749 strata over 90% of the firms are an audits. Conversely, in the 100- Generally, CPAs who do a larger amou nt of audit work report that they considered to be “specialized” firms. do specialize in EBP audits. Note: A firm is considered to be specialized if its EBP practice accounts for at least 20% of the revenue for its total audit practice. Statistics are calculated using sample weights, which account for the different amount of audits performed by each st ratum. For this reason, the population average may be different from the un-weighted sample averages. firms considered to be “spec ializing” in EBP audits, we looked at CPA firms which With the wide variation of had an audit with at least one major GAAS defici ows the distribution of ency. The chart below sh “specialized” CPA firms with at least one major GAAS de ficiency in their audit work. The chart clearly shows that the largest proportion of CPAs performing audits with at least one major GAAS deficiency are not EBP specialists. This is consistent with our finding that CPA firms with smaller EBP audit practices tended to have the highest deficiency rates. 12

15 Are Practice Monitoring and Pe er Review Activities Related to Improved Audit Quality? For the 232 sampled CPA firms we obtained peer review information (where applicable). The audit study ring efforts have not resulted in ’s peer review and practice monito showed that the accounting profession tifying deficient audit engagements. improved audit quality or in iden 5 require that CPAs performi ng attest engagements partic ipate in a qualifying peer Most state licensing boards The AICPA’s Peer Review staff estima te that about 27,000 CPA firms are review/practice monitoring program. 6 eer reviews are performed on an annual basis. subject to peer review and that 9,000-10,000 p As part of its review, EBSA obtained peer review repo the study. The distribution rts for the 232 CPA firms in own in the chart below. In general, it is estimated that a large portion of results of these peer reviews are sh of the peer reviews of the auditor population end wi peer review. In addition, th the auditor passing the smaller auditors have no opinion rendered more ofte n than larger auditors, wh ich may be due to a peer review not being performed. EBSA found that in 4 of the 6 audit strata, a substant ial number of CPA firms rece ived an acceptable peer review report yet had deficiencies in the audit work th at EBSA reviewed. As the table below highlights, in the 1-2 plan audit stratum, 52% of the deficient audits d or “clean” peer review had received an unqualifie report. Because these firms perform few employee benefit plan audits, there is a good chance that the audit engagement reviewed by EBSA was also the same audit engagement ex amined by the CPA firm’s peer reviewer. 5 The Delaware and Puerto Rico licensing boards do not requir e CPAs to participate in a practice monitoring/peer review program. Florida, Hawaii and the U.S. Virgin Islands have passed a practice monitoring statute, but it is not yet effective. 6 Many CPA firms perform audit and attest engagements that do not involve employee benefit plans. The larger number of CPA firms subject to “peer review” includes those CPA firms. 13

16 Clean Peer Reviews Deficient Audits and by Statum Deficient Audits With Clean Peer Review Report Strata (Audits) 52% (49) 1-2 58% (55) 3-5 63% (60) 6-24 40% (26) 25-99 12% (3) 100-749 4% (1) 750+ Given the results showing that an alarming number of p eer review reports fail to highlight employee benefit plan audit deficiencies, EBSA looked at the results of peer reviews that did not properly identify CPA firms that perform significantly deficient plan audits (chart below). Audits Containing Multiple Deficiencies and Clean Peer Reports by Stratum Deficient Audits With Five or More Deficiencies and a Clean Peer Strata (Audits) Review Report 35% (33) 1-2 36% (34) 3-5 37% (35) 6-24 22% (14) 25-99 4% (1) 100-749 4% (1) 750+ As reflected in the table above, even audits that had five or more deficiencies often received a clean peer review report. Indeed, in three of ent audits had received acceptable the six strata, over 35% of such defici peer review reports. Is Membership in the AICPA’s Employee Benefit Plan Audit Quality Center (EBPAQC) Related to Audit Quality? information regarding memb ership in the AICPA’s For those 232 sampled CPA firms, EBSA also gathered Employee Benefit Plans Audit Quality Center (EBPAQC). The chart below shows the distribution of EBPAQC members spread out among the six audit strata. EBPAQC Members by Stratum EBPAQC Non-EBPAQC TotalFirms Member Member Strata 95 1-2 11 (12%) 84 (88%) 95 68 (72%) 3-5 27 (28%) 15 (79%) 4 (21%) 19 6-24 13 1 (8%) 12 (92%) 25-99 100-749 5 (100%) 0 (0%) 5 750+ 5 (100%) 0 (0%) 5 157 (68%) 232 75 (32%) t al To 14

17 As the chart shows, overwhel mingly, most CPAs in the 1-2 and 3-5 au dit strata are not EBPAQC members. These are the two strata that have the highest number of audits not in compliance with professional standards. art show the deficiency rates for bo th EBPAQC members and non-EBPAQC The following table and ch members, across multiple stra EBPAQC members had a lower deficiency ta. For all strata, audits performed by rate than audits performed by non-EBPAQC members. Audit Deficiency Rate by Stratum and EBPAQC Membership Status EBPAQC EBP-ACQ Auditor Size Members Nonmembers 77.4% 63.6% 1-2 Plans 55.6% 73.5% 3-5 Plans 60.8% 90.5% 6-24 Plans 100.0% 36.7% 25-99 Plans N/A 12.0% 100-740 Plans 12.0% N/A 750+ Plans All Auditors 82.3% 29.9% Audit Deficiency Rate by EBPAQC Membership Status larger number of GAAS deficiencies EBSA’s analysis also shows that non EBPAQC member firms tend to have a per audit engagement than EBPAQC me mbers. For example, in the 1-2 audi t stratum, 90% of the audits that contained five or more audit deficiencies were pe rformed by CPA firms that are not EBPAQC members. Similar results exist in the 3-5 audit stratum where 77% of the audits with five or more deficiencies were performed by non EBPAQC member firms. 15

18 Does the Level of Employee Benefit Plan Specific Continuing Professional Education by Engagement ct on Audit Quality? Partners Have an Effe quire that auditors have the compet ence and capabiliti es necessary to Established professional standards re perform professional audits. Employee benefit plan audits exist in an envi roment that is specialized, highly regulated, and subject to governmental oversight. As a part of the audit quality study, EBSA gathered information regarding the number of hours of employee ucation (CPE) taken within the three years preceeding benefit plan (EBP) specific continuing professional ed The information gathered showed the following: the performance of the selected audit engagement.  Audit partners in firms performing a greater number of plan audits tended to have taken more hours of EBP specific CPE. The level of EBP specific CPE was a contributing factor in audit quality as the percentage of audits  containing one or more deficient areas of audi t decreased as more EBP specific training was obtained.  The majority of engagement partners in firms performing 25 or more EBP audits annually indicated hours of EBP specific training in the 3 years preceeding the audit that they had obtained 8 or more ses, these engagement partners ha d obtained 24 or more hours of engagement reviewed. In most ca EBP specific CPE.  In contrast, engagement partners performing 24 or fewer EBP audits annua lly had obtained less EBP specific CPE within the 3 years pr eceding performance of the audit engagement and, in some cases, had received no training at all.  While the overall responsibility for the audit engage ment rests with the enga gement partner, it is to and performing the detailed audit work to have EBP specific just as important for those assigned training. 16

19 Were There Specific Audit Areas that Resulted In More De ficiencies than Other Areas? mple, EBSA looked at sixteen differe In reviewing the 400 audits in the sa nt audit areas to determine if the with previously discussed engagement was conducted in accordance with profession al standards. Consistent information, auditors in the two lower audit strata (1-2 plan audits and 3-5 plan audits) disproportionately accounted for deficient audits. Moreover, when CPAs in these two audit strata performed deficient audits, the audits tended to be deficient the chart below, CPAs in the 1-2 plan audit stratum had significantly high in multiple areas. As can be seen in dit areas that are unique to empl oyee benefit plans, most notably: deficiency rates spanning numerous au contributions, planning & supervision, internal cont rols, participant data, inve stments, party-in-interest milarly, the 3-5 plan audit stratum also contained high deficiency rates transactions and benefit payments. Si especially in the following audit areas: contributions, party-in-interest transactions, internal controls, benefit payments and participant data. Consistent with other fi ndings in this report, the two strata containing CPAs with the largest employee benefit plan audit practices had the lowest deficiency rate in the various audit areas. Deficiency Rates by Audit Area Appendix II contains a detailed breakdown of deficient audit areas by plan audit strata. As previously noted, many of the audits in the sample were limited-scope audit en gagements as permitted by ERISA and codified in 29 CFR 2520.103-8. This regulation allows plan ad ministrators to exclude from the scope of the auditor’s engagement elated transactions and income investments held and investment-r properly certified to by certain qualif ying entities. A detailed review of audits disclosed that almost 60% of the limited-scope audits in this study contained major GAAS deficiencies in areas of audit not related to investments. In these audits, CPAs had deficiencies in non-investment -related critical areas such as contributions, participant data, benefit payments and internal controls. These audit deficiencies may have t was being performed, plan auditors were not as occurred because, knowing that a “limited-scope” audi focused on all relevant audit areas. 17

20 Did Plan Audits Comply With ERIS A and DOL Reporting Regulations? adhering to GAAP and GAAS, respecti vely, the report of the IQPA must In addition to conforming with and also meet certain ERISA reportin ERISA section 103(a)(3)(A) and DOL g and disclosure requirements. regulation 29 CFR 2520.103-1(b) set fort h these reporting and disclosure re quirements. These reporting and disclosure requirements were enacted to ensure that users (the federal go vernment and plan participants and alert them to instances which could beneficiaries) were being provided with necessary information that may plan (e.g., fiduciary breaches) and/or its ability to pay plan benefits adversely impact the operation of the when due (e.g., losses from imprudent investments). Of the 400 plan audit reports reviewed , 67 (17%) of the audit reports failed to comply with one or more of sclosure requirements. ERISA’s reporting and di Of the 67 reports identified, the area(s ) of non-compliance were as follows: In 11 (16%) instances, the suppleme ntal schedule(s) required by  ERISA reporting and disclosure requirements were not at tached or pr epared. In 11 (16%) instances, the footnotes to the plan’s financial statemen ts were either incomplete or  missing entirely.  In 8 (12%) instances, the CPA’s audi as required by DOL regulations. t report was not manually signed,  In 7 (10%) instances, delinquent em ployee contributions were not prop erly reported or disclosed in the CPA’s report or the plan’s Form 5500 filing. What has been Done to Improve Audit Quality in the Last 25 Years? EBSA has performed two previous “b aseline” studies to assess the prog ress being made in improving audit quality. The Agency’s 1997 study indi cated that 19% of plan audits contai ned one or more deficiencies. A second study, performed in 2004, co ificantly declined and expressed ncluded that audit quality had sign concern that even the larges t auditing firms were performing deficient audit work. For over 25 years, EBSA has continued to take aggressive actions with re spect to improving the quality of employee benefit plan audits. Since its creation in 1988, a main function of OCA within EBSA has been to provide compliance assistance and en force the reporting and disclosure provisions of Title I of ERISA. In addition, OCA continues to be re sponsible for establishing and mainta ining liaison with private sector professional organizations and regulatory bodies rega rding accounting and auditi ng issues for employee benefit plans. One of OCA’s main goals is to improve the quality of employee benefit plan audits to ensure that participants and beneficiaries are receiving the statutory protections that these audits are intended to provide. Reporting Compliance Activities Since conducting its two previous studies, OCA has taken the followin g enforcement actions to ensure compliance with these provisions: ngs that failed to meet  Issuance of letters reject ing deficient/incomplete Fo rm 5500 Annual Report fili the reporting and disclosure provisions of ERISA. 18

21  s to evaluate the qual ity of the audit work Performance of approximately 5,000 workpaper review underlying the CPA’s report. Referral of practitioners to the AI CPA’s Professional Ethics Division and/or the respective state board  of accountancy for potential disciplinary action due to significantly deficient audit work.  th EBSA’s Office of Enforcement (OE). OE refers Establishment of a system of inter-office referrals wi ations discovered during to OCA potential ERISA reporting and disclosure viol fiduciary investigations of employee benefit plans. Likewise, OCA re fers potential fiduciar y violations to OE. Activities to Encourage Filer Compliance Since the issuance of the 1997 report, on several progra ms to encourage EBSA has initiated or expanded up filer compliance: EBSA has created and conducted various national outreach programs aimed at heightening  awareness and providing guidance to practitioners regarding the preparation of the Form 5500 Series Annual Report, current and emerging information regarding accounting and auditing issues formation regarding DOL’s ongoing enforcement impacting employee benefit plans, and general in efforts. Additional outreach prog med at front line state societies rams have been created and are ai of CPAs to provide guidance and heightened awareness to independ ent auditors who conduct audits of employee benefit plans, especia lly those CPAs who perform only a limited number of plan audits.  In March 2002, EBSA made major re visions to its “Delinquent Filer Voluntary Compliance Program.” The purpose of the program changes was to encour age filer compliance with the annual reporting obligations under Title I of ERISA through significantly reduced civil penalties. The Form 5500 Series Annual Reports underwent ma jor revisions to stream line the Form 5500 and  make it easier to complete. At the same time, th e instructions to the Form 5500 were clarified and y track the organization of the revise reorganized to more closel d Form 5500. Coincident with these major revisions to the Form 5500, EBSA participated in numerous technical conferences, webcasts and other public meetings intended to publicize release of the revised Form 5500 and educate plan filers about the changes.  EBSA implemented the new “all electr onic” Electronic Filing Acceptan ce System (EFAST), to process the Form 5500. The new all electr ed to utilize st ate-of-the-art onic processing system was design technologies to process the Form 5500 filings. This system gives filers immediate feedback about correcting reporting deficiencies prior to the filing being finalized.  In conjunction with implementation of the revised Form 5 500 and the new EFAST Processing System, EBSA also created a “Help Desk” function designed to answer filer questions and other technical inquiries. Since its inception in March 2000, the EBSA “Help Desk” has received over 500,000 requests for technical assistance an d responded to other filer inquiries. 19

22 Work With Professional Organizations In addition, DOL has worked closely with the AICPA and the Financial Accounting Standards Board (FASB) to update the guidance available to practitioners in this area. The following is a list of actions taken in an effort to address the findings and recommendations contained in EBSA’s previous two studies: EBSA continues to work with the  ng guidance for employee benefit FASB on issuing revised accounti plans.  EBSA continues its active involvement with the AICPA’s Employee Benefit Plans Technical Expert Panel.  EBSA works with the AICPA on revisions to the AICPA’s Audit an d Accounting Guide, Audits of Employee Benefits Plans . Annual updates to the Guide have b een issued since the Agency’s previous studies, and the AICPA published a comprehens ive revision to the audit guide in 2013.  EBSA has provided tech nical assistance and input to the AICPA for the yearly issuance of Audit Risk Alerts and Current In dustry Developments that are intended to provide information that may affect the annual audits performed on employee benefit plans.  EBSA has continued to su pport the AICPA’s annual National Conference on Employee Benefit Plans . This conference, created jointly by the DOL and the AI CPA in 1990, has grown into one of the AICPA’s largest conferences, with an average attendance of over 1,200 participants. In December 2001, the AI  CPA held the inaugural Benefit Plans and DOL Update Conference . This conference is designed to provide a “high level” ov erview of events in the employee benefit plan area t of the “audit season.” for partners and senior managers prior to the star A similar conference has been held annua lly since then. The AICPA continues to update it s self-study continuing profe ssional education programs for  employee benefit plan professionals.  The AICPA has incorporated, as part of one of its practice monitoring programs (peer review), the requirement that engagements selected for review “must” include an audit of an employee benefit plan.  The AICPA operates a “Technical Hotline” that is available to answer member questions on accounting and auditing related issues. AICPA Employee Benefit Plan Audit Quality Center In October 2003, the AICPA Board of Directors approved the develo pment and implementation of an Employee Benefit Plan Audit Quality Center (“Center”) with the goal of improving the quality of employee benefit plan audits. The Center is composed of a community of CPA firms who, through voluntary membership, have made a commitmen t to audit quality by adhering to the Center’s membership requirements affecting their management practices, incl uding the designation of a partner-in-charge of the quality of the firm’s employee benefit plan audit prac tice. The Center’s member ship requirements also include obtaining employee benefit plan specific tr aining; establishing and ma intaining quality control practices and procedures specific to the firm’s empl oyee benefit plan audit practice; self-monitoring of adherence to policies and procedures ; and making the results of their external peer review of their audit the AICPA offers its members an extensive range of practice publicly available. Through the Center, 20

23 resources to help firms provide qu ality service to plans, including re gulatory and legislative guidance, practice aids, training opportunities, tools, and research. d representing all 50 stat es and the District of Over 2,300 CPA firms, employing 31% of plan auditors an AICPA’s Employee Benefit Plan Audit Qual ity Center. It is Columbia, have joined the estimated that the Center’s member firms perform over 60% of a ll employee benefit plan audits annually. Public Company Accounting Oversight Board (PCAOB) The PCAOB is a private-sector, non-pr ofit corporation, created by the Sarbanes-Oxley Act of 2002 (Act), to oversee the auditors of public companies in order to pr ors and further the public otect the interests of invest interest in the preparation of inform ative, fair, and independent audit re ports. Section 103 of the Act directs the Board to establish auditing and related attestation, quality control, ethics, and independence standards and rules to be used by registered pu blic accounting firms in the preparat ion and issuance of audit reports as required by the Act or the rules of th e Securities and Exchange Commission. The PCAOB has the authority to adopt anies and to regularly inspect the auditing standards for public comp operations of accounting firms regist ered with the Board. The PCAOB ma y discipline, fine, suspend, or bar ed accounting firm has engaged in firms where it finds that a register any practice in violation of the Sarbanes-Oxley Act, securities la w, or professional standards. PCAOB do not specifically apply to While the standards established by the all firms auditing employee benefit plans, firms complying with the standards established by the PCAOB ge nerally apply these standards to all of their audit engagements, including their non-pu blic employee benefit plan audit clients. Department of Labor – Office of Inspector General (OIG) For almost thirty years, the OIG, with EBSA’s support, has been recommend ing legislative changes to ERISA in order to strengthen the quality of employee benefit plan audits. The OIG has conclu ded that EBSA’ efforts to improve the quality of employee benefit plan audits have been impaired by EBSA’s current inability to take direct action against auditors who perform substand ard audits. As a result, the OIG recommended that ERISA be amended to provide EBSA with the authorit y over registration, suspension and debarment of the ability to levy civil penalties against auditors employee benefit plan auditors and that EBSA be given performing substandard audits. 21

24 Conclusions there had been no statistical change in the quality of plan EBSA’s 1997 audit study concluded that OIG in 1989. EBSA’s 2004 audit quality audits when compared to the original study performed by the study found that audit quality had gotten worse since the previous study and that the deficient audit work was starting to spread to the largest of the CPA firms. The original OIG study disclosed an audit deficiency rate of 23%. EBSA’s 1997 follow-up stud y resulted in a 19% deficiency rate (not a big enough improvement in audit quality to be considered statistically va lid). The Agency’s more recent a 33% deficiency rate for th e plan audits reviewed. study in 2004 resulted in Based on the results of the current audit review, a 39% overall deficiency rate for plan audits, it audits has not improved. Instead, audit quality appears that the quality of employee benefit plan continues to trend in the opposite direction with almost 4 out of 10 plan audits failing to comply with professional accounting an d auditing standards. Based on additional analysis, EBSA also concludes that:  Once again, the smaller the CPA firm’s employ ee benefit plan audit practice, the greater the incidence of audit deficiencies. Audit areas that are unique to employee be nefit plans such as contributions, benefit  payments, participant data and party-in-interest/ prohibited transactions, continue to lead the list of audit deficiencies. As found in the two previous studies, CPAs too often failed to consider these unique audit areas and, ther efore, performed inadequate audit work.  CPAs failed to comply with pr ofessional standards either beca use they were not adequately informed about employee benefit plan audits or failed to properly utilize the technical materials that were in their po rms performing a greater number ssession. Audit partners in fi of plan audits tended to have a greater amount of employee benefit plan specific training. However, in a number of instances, having the pr oper technical guidance did not ensure that a quality audit was performed.  The Practice Monitoring Peer Review process established by the AICPA and administered by sponsoring state CPA societies does not appear to be an effective tool in identifying deficient plan audit work and ensuring compliance with professional standard s. While selecting an employee benefit plan audit is a required part of the peer review proce ss (where applicable), CPAs who performed deficient audits often re ceived acceptable peer review reports.  Members of the AICPA’s Employee Benefit Plan s Audit Quality Center (EBPAQC) tend to conduct fewer audits containing multiple G AAS deficiencies. Additionally, non EBPAQC member firms tend to have more GAAS defi ciencies per audit engagement than EBPAQC members. 22

25 Recommendations is report, EBSA makes To address the deficiencies identified in th the following eleven recommendations. Enforcement 1. Revise case targeting to focus on: CPA firms with smaller employee benefit plan audit practices that audit plans with a. large amounts of plan assets, and b. CPA firms in the 25-99 plan audit stratum gi ven their high deficiency rates and the amount of plan assets ($317.1 billion) and pl an participants (9.3 million) at risk from deficient audits. 2. Work with the National Association of State Bo ards of Accountancy (NASBA) and the AICPA to improve the investigation and sanctioning proc ess for those CPAs who perform significantly deficient audit work. Work with NASBA to get state boards of accountancy to accept the results of investigations perfor med by EBSA and the AICPA’s Prof essional Ethics Division, in order to use those results in disciplining CPAs (at the state licensing board level). 3. Amend ERISA to make sure the annual reporting ci vil penalties focus on th e responsible party. Under this proposal, the Secretary of Labor woul d be authorized to asse ss all or part of the current annual reporting civil penalty of up to $1,100 per day against the accountant engaged to do an ERISA plan audit if the plan’s annual report is rejected due to a deficient audit or dards for being qualified to perform an ERISA because the accountant failed to meet the stan plan audit. 4. Work with the AICPA’s Peer Review staff: to streamline the peer review process an a. ctive at improving d make it more effe employee benefit plan audit quality. b. to ensure that CPAs who are required to undergo a peer review have in fact had an acceptable peer review. c. to identify those CPAs who have not receiv ed an acceptable peer review and refer those practitioners to the applicable state licensing boards of accountancy. Regulatory/Legislative 5. Amend the ERISA definition of “qualified public accountant” to include additional requirements and qualifications necessary to ensure the quality of plan audits. Under this proposal, the Secretary of Labo r would be authorized to issu e regulations concerning the qualification requirements. 6. Amend ERISA to repeal the limited-scope au dit exemption. This exemption prevents ans’ financial statements for assets held in accountants from rendering an opinion on the pl 23

26 regulated entities such as financial institutions. An alternative to the repeal of the limited- scope audit would be to provid ity to define when a limited- e the Secretary with the author substitute for a full audit. When auditors have to issue a scope audit would be an acceptable formal and unqualified opinion, they have a powerful incentive to rigorously adhere to professional standards ensuring d scrutiny. The limited scope that their opinion can withstan audit exemption undermines this incentive by removing auditors’ obligations to stand behind the plans’ financ ial statements. Amend ERISA to give the Secretary of Labor authority to establish accounting principles and 7. audit standards that would protect the integrity of employee benefit plans and the benefit neficiaries. Under th is approach, the Secretary of Labor would security of participants and be be authorized to establish standards that addr ess financial reporting i ssues that are either upon employee benefit plans. unique to or have substantial impact Outreach 8. Work with the NASBA to encourage state boards of accountancy to require specific licensing t plan audits. This would include specific requirements for CPAs who perform employee benefi dits of employee benefit plans. training and experience in the au 9. Expand EBSA’s outreach activities to include: a. plan administrator organizati ons (e.g. ASPPA), to explain to plan administrators and those with responsibility for hiring plan au ditors, the importance of hiring competent CPAs. Using information contained in the EFAST2 database, send targ eted correspondence b. to: plan administrators in the 1-2 and 3- 5 plan strata highlighting the high i. deficiency rate among plan auditors and providing information about how to select a qualified plan auditor. ii. CPA firms in the 25-99 stratum discussi ng the audit deficiencies found in EBSA’s audit study and working with th e firms to ensure that plan audits comply with professional standards. 10. Communicate with each of the state boards of accountancy (licensing boards) regarding the results of the audit study and th e need to ensure that only competent CPAs are performing employee benefit plan audits. 11. Expand EBSA’s outreach with individual state societies of CPAs who have a large number of plan audits performed by CPA firms in the 1-5 plan audit stratum. For those states that do not already do so, encourage them to create em ployee benefit plan audit training programs. 24

27 Appendix I Objectives, Scope and Sample Composition Objectives The primary objective of this st udy was to assess whether the le vel and quality of audit work performed by CPAs with respect to audits of empl d by ERISA has improved oyee benefit plans regulate since OCA’s previous comp rehensive study in 2004. Specific objectives of the review were to:  assess whether plan audits were conducted in accordance with professional auditing and accounting standards;  determine if the audit reports complied with ERISA reporting and disclosure requirements; and  identify areas that ma y need improvement. Scope EBSA’s assessments involved a revi ew of the Form 5500 Annual Return/Report filings and related audit reports for the 2011 filing year (plan years beginnin g in 2011). EBSA selected a statistically valid sample of 400 plan audits from a target population of 81,162 Form 5500 filings for 2011 in which an accountant’s repo rt/audit opinion was attached. For the 400 plan audits selected, EBSA’s assessment included: a review of the plan year 2011 Form 5500 A nnual Report and the related IQPA report;   a detailed review of the audit workpapers for the 2011 plan year audit;  determining whether the CPA was properly licensed by the applicable state licensing board;  if applicable, reviewing the peer review report of the CPA’s audit practice; and voluntary demographic questionnaires given to each of the CPAs in the audit sample.  The workpaper reviews, performed at EBSA’s office , were conducted during the period December 2013 through September 2014. The 400 selected audit reports were ev aluated based on the AICPA’s Audit and Accounting Guide, Audits of Employee Benefit Plans (with co nforming changes as of January 1, 2012) . 25

28 Sample Composition The following charts depict the composition of the sample of the 400 plan audits reviewed during this study. Type of Plan 100% 80% Of the 400 plan audits D C Pension Plan 60% reviewed, 89% involved D B Pension Plan defined contribution (DC) 40% Welfare Plan pension plans, 6% defined benefit (DB) pension plans 20% and 5% welfare plans. 0% Type of Audit 90% 80% 70% 60% Of the 400 plan audits Limited-Scope Audit reviewed, 19% involved 50% full-scope audits and 81% 40% F ull Scope Audit limited-sco p e audits. 30% 20% 10% 0% Type of Plan Sponsor 100% 90% 80% Of the 400 plan audits Single Employer 70% reviewed, 95% involved 60% single employer plans, 3% Multi-Employer 50% multi-employer plans, and 40% 2% multiple employer Multiple plans. 30% Employer 20% 10% 0% 26

29 Appendix II Audit Deficiencies by Type of Deficiency Percentage of Standard Lower Upper Deficiency Type Audits With Error Bound Bound Deficiencies 1.6% 3.8% 7.0% 10.2% Planning and Supervision 4.2% 1.0% 2.2% 6.3% Investments 4.9% 11.3% 8.1% 1.6% Contributions Received 4.8% 7.8% 1.5% 10.8% Benefit Payments 10.8% 1.5% 7.8% 4.8% Participant Data 3.7% 0.9% 1.4% 6.6% Plan Obligations 6.6% 1.4% 3.9% 9.3% t Party In Interes 1.1% 2.2% 6.7% 4.4% Plan Tax Status 5.1% 1.0% 3.1% 1.1% Commitments and Contingencies 18.3% 2.5% 13.8% 23.7% Internal Controls 4.9% 7.3% 2.6% 1.2% Administrative Expenses 7.3% 4.9% 1.2% 2.6% Subsequent Events 2.6% 4.9% 1.2% 7.3% Plan Representations 8.0% 1.0% 6.0% 4.0% Compliance Reporting 4.4% 6.1% 2.8% 0.8% Compliance with ERIS A 3.6% 5.6% 1.5% 1.0% Notes Receivable 33.9% 40.4% 27.4% 3.3% All Deficiencies audits performed fferent amount of le weights, which account for the di Statistics are calculated using samp Note: by each stratum. For this reason, the population average may be different from the unweighted sample averages. 27

30 Planning & Supervision Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Totals Acceptable Strata Minor Major Minor 10 9 35 95 41 1-2 plans 62 3 21 95 9 3-5 plans 11 4 27 95 53 6-24 plans 43 11 3 8 65 25-99 plans 2 0 1 25 22 100-749 plans 23 0 1 25 1 750+ plans 244 44 19 93 Totals 400 Unacceptable, Major Membership in AIPCA Employee Be nefit Plan Audit Quality Center Strata Yes No Totals 35 3 32 1-2 plans 21 4 17 3-5 plans 15 27 12 6-24 plans 5 3 8 25-99 plans 1 0 1 100-749 plans 1 0 1 750+ plans 29 64 Totals 93 le major findings identified in planning and supervision and the The following details the unacceptab number of occurrences. Description of Unacceptable, Major Finding # 3 Audit performed and report issued by an "unlicensed" auditor 1 No audit performed, auditor perfor med and issued a "review" report No/insufficient review of plan documents/plan operations 49 No evidence of required communications (114/115) 37 No/lack of evidence of audit planning 25 21 No/inadequate evidence of planning analytics with developed expectations 19 No/insufficient audit program 15 No/inadequate assessm ent of fraud risk 14 No/inadequate procedures on initial/beginning balances 8 No evidence of planning materiality 6 No/inadequate review of audit workpapers or engagement not adequately supervised nt partner review was completed 4 Inadequate supervision - engageme after report issuance date 28

31 3 Failure to document current de velopments affecting the plan to predecessor auditor 3 No/inadequate work related 2 No/incorrect engagement letter Improper performance of limited scope audit 2 1 Missing plan document s in permanent file No evidence of review of se rvice provider agreements 1 Inadequate identification of parties in interest for planning 1 Unsigned plan adopti icipant agreements 1 on agreements and part Incorrect industry audit guide was used which resulted in no 1 identification of parties in interest 1 Failure to verify balances tr ansferred from/to new custodian 1 No evidence $1M insurance cont ract was obtained/reviewed for disclosure and accounting treatment 1 ed, however, the engagement partner Audit firm was not properly licens was properly licensed 1 Audit planning did not address the $4.7M rollover into this new plan in 2011 No planning documentation of prior year known issues 1 1 No evidence of planning inquiries 1 Failure to document and assess sign ificant decrease in net assets and large amount of benefit payments 1 No evidence of IQPA consideratio n of plan termination in planning audit procedures for liquidation ba sis for investments and accumulated benefit obligations 1 Failure to gain an understanding of the plan 1 No evidence of planning related to testing of mid-year change in trustee/recordkeeper 1 Audit partner did not participate in engagement team fraud brainstorming discussion 29

32 Internal Controls Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Totals Acceptable Strata Minor Major Minor 5 11 42 95 37 1-2 plans 49 3 34 95 9 3-5 plans 11 5 31 95 48 6-24 plans 38 10 3 14 65 25-99 plans 4 1 0 25 20 100-749 plans 18 0 1 25 6 750+ plans 210 45 23 122 400 Totals Unacceptable, Major nefit Plan Audit Quality Center Membership in AIPCA Employee Be Yes No Strata Totals 2 40 42 1-2 plans 9 25 34 3-5 plans 23 31 8 6-24 plans 12 2 14 25-99 plans 0 0 0 100-749 plans 1 0 1 750+ plans 47 75 Totals 122 le major findings identified in The following details the unacceptab internal controls and the number of occurrences. # Description of Unacceptable, Major Finding 3 Audit performed by an "unlicensed" auditor 1 Possible fraud discussed in board minutes but engagement team did not inquire of legal counsel or incl ude it as a fraud risk factor No/inadequate documentation of internal control environment 52 Failure to assess/document control risk 37 No evidence of SOC1 repo rt review and/or reliance 37 29 No/inadequate evidence of fraud "brainstorming" 27 Lack of documentation of risk assessment procedures 22 ntrols of service provider(s) Failure to review internal co 17 Failure to document evaluation of internal control 15 No/inadequate evidence of fraud inquiries 12 No evidence of work performed Failure to document asse ssment of user controls 4 30

33 4 Failure to obtain bridge/gap letter for period not covered by SOC1 report 3 Failure to identify and document significant audit areas 2 Failure to document assessment of control risk below maximum 2 Inconsistency in documentation of risk assessments SOC1 report does not cover significan 2 t period of plan year and no work performed to address such 1 Failure to obtain and review SOC1 report covering 6 months of the plan year 1 Failure to document risk of material misstatement 1 Unclear documentation of low & moderate inherent control risk was determined based on errors in prior years in contributions 1 Failure to identify and review user controls of third party service providers 1 Partner not involved in fraud brai nstorming; Sole trustee and person responsible for governance not interviewed for fraud 1 Fraud brainstorming did not include in-charge who performed most audit work 1 Failure to identify audit risks re lated to liquidation basis of non- marketable investments and accumu lated benefit obligations on the liquidation basis, nor benefit payments subsequent to plan termination 1 Failure to document inherent/control risk or combined risk for each significant audit area Failure to document COSO (Commi ttee on Sponsoring Organization) 1 plan sponsor controls 1 Failure to document activity level in ternal controls at plan sponsor level 1 Inappropriate reliance on SSAE 16 to assess risk in significant audit areas 1 Lack of evidence to suppor t reduction in control risk 1 rstanding of the plan's internal control No evidence of unde environment at the cycle, ac count, transaction level 1 Inadequate assessment of control risk 1 Fraud brainstorming and inquiries made after audit report date nform with actual level of work 1 Control risk assessments do not co performed 31

34 Investments – All Audit Combined Audit Quality Study Review Results Acceptable Acceptable, Unacceptable, Totals Unacceptable, Strata Minor Minor Major 53 5 4 33 95 1-2 plans 95 71 5 2 17 3-5 plans 6 1 13 95 75 6-24 plans 54 2 0 9 65 25-99 plans 23 2 0 0 25 100-749 plans 22 3 0 0 25 750+ plans Totals 298 23 7 72 400 Unacceptable, Major nefit Plan Audit Quality Center Membership in AIPCA Employee Be Strata Yes No Totals 4 29 33 1-2 plans 2 15 17 3-5 plans 13 11 2 6-24 plans 8 1 9 25-99 plans 0 0 0 100-749 plans 0 0 0 750+ plans Totals 25 47 72 Note: The detail breakout of investments full scope and limited scope following this combined chart does not include the one (1) plan selected where a “review” engagement was performed. 32

35 Investments – Full Scope Only Audit Quality Study Review Results t able, Unacceptable, Accep Unacceptable, Strata Acceptable Totals Major Minor Minor 3 1 0 1-2 plans 19 15 3-5 plans 1 0 7 24 16 7 1 0 6 14 6-24 plans 16 11 0 0 5 25-99 plans 1 0 0 1 0 100-749 plans 4 1 0 0 5 750+ plans Totals 41 5 0 33 79 Unacceptable, Major Membership in AIPCA Employee Be nefit Plan Audit Quality Center Strata Yes No Totals 1-2 plans 1 14 15 1 7 6 3-5 plans 6 6 0 6-24 plans 4 1 5 25-99 plans 0 0 0 100-749 plans 750+ plans 0 0 0 12 21 Totals 33 The following details the unacceptab le major findings identified in investments for full scope audits performed and the number of occurrences. # Description of Unacceptable, Major Finding 1 Audit performed by an "unlicensed" auditor 18 Failure to test investment transactions 14 investment income Failure to test 7 Failure to test end of year asset values 5 No evidence of work performed 4 Inappropriate reliance on SOC1 report 4 Insufficient work performed 4 Failure to confirm investments - evidence of existence 2 No review/testing of investme nt valuation assumptions (ESOP) 2 Inadequate evidence of confirma tion of investment ownership and existence with custodian 2 Failure to adequately test change in service provider Failure to test assets transferred from the plan 1 33

36 1 n spec.'s qualifications No assessment of valuatio 1 Failure to document work performed related to cash 1 Failure to address liquidation basi s of non-marketable securities and insurance contracts 1 Failure to adequately test cost basis of non-participant directed investments 1 Failure to test end of year valu es for investments in self-directed brokerage accounts 1 Insufficient testing of dividend income (ESOP) 1 atements did not agree to the Investments per the financial st confirmed trust statement 1 Failure to adequately identify plan 's investment medium at the end of year 1 Principal IPG contract was excluded from plan's financial statements; there was no copy of the contract in the au dit file; there was no accounting analysis supporting the conclusion for excluding the financial statement reporting investment from the plan’s 34

37 Investments – Limited Scope Only Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Strata Acceptable Totals Minor Major Minor 50 4 4 17 75 1-2 plans 71 55 4 2 10 3-5 plans 5 6-24 plans 68 81 7 1 2 0 4 49 43 25-99 plans 23 0 24 100-749 plans 0 1 18 2 0 0 20 750+ plans 257 320 38 7 Totals 18 Unacceptable, Major nefit Plan Audit Quality Center Membership in AIPCA Employee Be Yes No Totals Strata 14 17 3 1-2 plans 3-5 plans 1 9 10 6-24 plans 5 7 2 4 4 25-99 plans 0 0 0 0 100-749 plans 0 0 0 750+ plans 38 25 13 Totals able major findings identified in investments for limited scope The following details the unaccept audits performed and the num ber of occurrences. # Description of Unacceptable, Major Finding 2 Audit performed by an "unlicensed" auditor 10 Audit workpapers do not contain the certification 6 Failure to adequately test change in service provider 5 Certifying entity does not qualify for limited scope nsistent with plan reporting period Certification not co 3 Uncertified investments/transactions not audited 3 3 Unsigned certification 3 No list of plan investments and/or transactions certified included with the certification 2 Certification is not for the plan 2 No comparison/reconciliation of ce rtified income to amount reported on financial statements 2 Certifying entity identified in report not consistent with certification ract to fair va 1 Inappropriate treatment of cont lue adjustment 35

38 1 No audit program 1 Certification did not mention the plan name nor period covered 1 Failure to test assets transferred from plan 1 Certification obtained 3/21/ 14, audit report dated 10/5/12 1 Trust report prepared by and obtained from the recordkeeper 1 Investments per trust do not agree to financial statements 1 Failure to gain understanding of plan's common/collective trust and stable value funds 1 Inadequate evidence of evalua tion of GIC for accounting and presentation Failure to evaluate insurance cont 1 ract, contract to fair value, and whether it was fully-benefit responsive Failure to analyze pooled separate account for investments in common 1 collective trust/stable value funds 1 Unexplained variance in certified participant loan total 1 Dividend income and net appreciation do not tie to financial statements 1 No documentation supp orting fair value repo rted on 5500 - amount marked up to fair valu e without corresponding ad justment to contract value 1 Certification obtained from trustee for master trust – certification at was not a qualifying entity and was plan level obtained from entity that not an agent for the trustee 36

39 Notes Receivable Audit Quality Study Review Results Acceptable, Unacceptable, Acceptable Unacceptable, Totals N/A Strata Major Minor Minor 4 3 20 34 95 34 1-2 plans 31 4 13 43 95 4 3-5 plans 3 6 16 24 95 46 6-24 plans 35 1 1 2 26 65 25-99 plans 0 0 0 14 25 11 100-749 plans 16 25 0 0 9 0 750+ plans 51 12 Totals 14 173 150 400 Unacceptable, Major Membership in AIPCA Employee Be nefit Plan Audit Quality Center Yes No Totals Strata 18 20 2 1-2 plans 4 9 13 3-5 plans 7 9 16 6-24 plans 1 2 1 25-99 plans 0 0 0 100-749 plans 0 0 0 750+ plans Totals 14 37 51 The following details the unacceptab notes receivable and the number of le major findings identified in occurrences. # Description of Unacceptable, Major Finding 2 Audit performed by an "unlicensed" auditor 21 No work performed 30 No/inadequate testing of compliance with plan 7 No review of supporti ng loan documentation 5 No/inadequate testing for determination of delinquent loans that should be reported as deemed distributions 4 No audit program 3 No listing of outstanding loans 2 No evidence of test of loan interest 2 No work performed on participant loans which were not covered by the limited scope certification 1 No testing of transfer to new custodian 1 Inadequate consideration of error in loan reporting on financial statements 37

40 1 Inadequate documentation as to th e source of listing of participant loans for completeness and accuracy 38

41 Contributions Received & Receivable Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Acceptable N/A Totals Strata Minor Major Minor 44 5 6 40 1-2 plans 95 0 3-5 plans 4 6 37 1 95 47 51 10 5 27 2 95 6-24 plans 25-99 plans 50 6 2 6 1 65 23 1 0 0 25 1 100-749 plans 2 1 1 0 25 21 750+ plans Totals 236 28 21 111 4 400 Unacceptable, Major Membership in AIPCA Employee Be nefit Plan Audit Quality Center Yes Strata No Totals 3 40 37 1-2 plans 6 31 37 3-5 plans 17 10 27 6-24 plans 5 1 6 25-99 plans 0 0 0 100-749 plans 1 750+ plans 1 0 111 t 32 To als 79 The following details the unacceptable major findings identified in co ntributions received & receivable and the number of occurrences. # Description of Unacceptable, Major Finding 3 Audit performed by an "unlicensed" auditor 1 out potential missing contributions Failure to identify or inquire ab occurring in time period leading up to plan admin termination and his possible conversion, fraud and theft 53 Failure to test timely remittance of employee contributions 35 Failure to test compliance with plan compensation provisions 24 No/Inadequate testing of use of forfeitures 10 Failure to agree/reconcile contri butions to plan sponsor payroll records, employee records, custod ian/trust, and/or Schedule H 10 No/inadequate testing of rollover contributions (material amount) 9 No work performed 7 Failure to address testing errors an d/or variance and their impact on financial statements No/inadequate testing of contribution receivable(s) 5 39

42 5 Inadequate testing/documentation of recalculation of contributions/deferrals 3 mpliance with the plan document Failure to test rollovers for co 2 Insufficient work performed of contributing employers (multi-employer plans) 2 No audit program 2 No schedule of contribution s received &/or receivable 2 Failure to recognize untimely employee contributions 2 Failure to review criteria for contribution receivables and recording per GAAP Inadequate documentation related to late remittances 2 1 Failure to agree contributions to actuarial report 1 Failure to adequately test ti ming of employee contributions 1 No testing of ROTH contributions 1 Inappropriate reliance on SOC1 Report 1 Failure to consider plan's funding status (DB plan) 1 No contributions withheld from a bonus and no testing to determine the propriety of such 1 Failure to verify employer discretionary percentage 1 No disclosure of corrective distributions in the plan's financial statements and notes 1 Failure to document recalculation of employer match 1 Failure to adequately communicate delinquent remittances to management of contributions 1 No schedule/listing 1 Testing of employer matching contribution did not adequately address the apparent failure by the spon sor the match the required 3% of compensation 1 Failure to evaluate any required em ployer receivable that might result from any unfunded accumulated benefi t obligation resulting from plan termination 1 Failure to identify inconsistency in COBRA contributions 1 Failure to determine if reinsu rance receivable was complete 1 Inadequate testing of recalc ulation of employee deferrals 1 Inadequate sample size 1 Receivable improperly accrued 1 Delinquent contributions reported on supplemental schedule differed to that reported in the workpapers and on Schedule H 40

43 1 Inadequate testing of employer contributions which appear to not be made in accordance with the plan 1 Failure to compare amount of em ployer contributions to amount approved by the Board of Directors 1 Eligibility testing did not include test of end of year employment requirement 1 Inadequate consideration of impact of non-correction of prior year errors on current year's work & financial statements 1 Lack of documentation for support of employer contribution formula 1 Lack of identification of improper use of forfeitures to offset employer contributions prior to plan expenses being paid 41

44 Benefit Payments Audit Quality Study Review Results Totals N/A Unacceptable, Acceptable Unacceptable, Acceptable, Strata Major Minor Minor 11 44 35 0 95 1-2 plans 5 59 8 2 26 0 95 3-5 plans 53 8 26 2 95 6 6-24 plans 54 5 1 4 1 65 25-99 plans 23 0 2 0 25 0 100-749 plans 1 0 0 0 25 24 750+ plans Totals 257 31 16 93 3 400 Unacceptable, Major Membership in AIPCA Employee Be nefit Plan Audit Quality Center Strata Yes Totals No 2 33 35 1-2 plans 22 26 4 3-5 plans 15 11 26 6-24 plans 3 1 4 25-99 plans 0 2 2 100-749 plans 0 0 0 750+ plans Totals 26 67 93 The following details the unacceptab le major findings identified in benefit payments and the number of occurrences. Description of Unacceptable, Major Finding # 3 Audit performed by an "unlicensed" auditor 41 No recalculation of benefit payments 38 ibility of individuals receiving No/inadequate work regarding elig benefit 28 No work performed 19 No/inadequate work regarding validity of claims 10 Inappropriate reliance on SOC1 report 9 No/inadequate work regarding forfeitures 7 Failure to trace benefit payments to individual participant's account 6 No/inadequate work regarding part icipant receipt of benefit payment 6 No/inadequate testing of hardsh ip/in-service benefit payments 3 No testing of rollovers out of plan for compliance with plan document No schedule/listing of benefit payments made 3 42

45 2 Inappropriate application of limited scope audit Total per financial statement was not reconciled to total per trust 2 report 2 No review of supporting documents and approvals No/inadequate testing for compliance with plan document 2 No testing of long outstanding benefit checks 1 1 Participant confirmation were not included in workpapers 1 No audit program 1 Inadequate follow up on error note d in benefit recalculation testing 1 Unreconciled difference in total benefit payments between distribution listing and that reported on the financial statements 1 No testing of correc tive distributions 1 No reconciliation of total benefit payments to total participant accounts 1 No agreement of benefit payment re calculations for compliance with formula in plan document 1 Failure to identify inconsistency in COBRA contributions but lack of reporting of dental and vision claims 1 Inadequate testing of propriety of payee 43

46 Participant Data, Including Individual Participant Accounts Audit Quality Study Review Results Unacceptable, Unacceptable, Acceptable, Strata Acceptable N/A Totals Minor Minor Major 7 6 59 0 1-2 plans 23 95 40 10 37 1 95 3-5 plans 7 12 12 37 2 95 6-24 plans 32 16 8 6 25-99 plans 0 65 35 100-749 plans 1 0 1 0 25 23 17 2 1 0 25 5 750+ plans 170 40 36 Totals 151 3 400 Unacceptable, Major Membership in AIPCA Employee Be nefit Plan Audit Quality Center Strata Yes No Totals 6 53 59 1-2 plans 7 37 30 3-5 plans 22 15 37 6-24 plans 13 3 16 25-99 plans 1 0 1 100-749 plans 1 0 1 750+ plans 50 Totals 151 101 The following details the unaccept able major findings identified in participant data, including individual participant accounts, and the number of occurrences. # Description of Unacceptable, Major Finding 3 Audit performed by an "unlicensed" auditor Failure to adequately test allocations to participant accounts 89 No/insufficient testing of payroll data 73 68 icipant investment options No/Inadequate testing of part 41 No reconciliation of total individual participant accounts to total plan assets 35 Failure to adequately test eligibil ity, terminations and forfeitures 29 plan compensation provisions Failure to test compliance with 18 No work performed 10 Failure to adequately test change in service provider 10 Inappropriate reliance on SOC1 report 2 No audit program 2 Inadequate testing of participant deferral percentage 44

47 1 No testing of participant accounts at time of change in trustee/third party administrator Failure to obtain or evaluate any ce nsus data based on premise that an 1 actuarial report did not need to be obtained for a terminated plan No testing for compliance with IRS deferral limits 1 1 Failure to test participant opening balances audited by another auditor 1 Failure to test payroll process 1 Inadequate evidence obtained of tr ansfer of $2.3M to an affiliated entity benefit plan Failure to test that newly eligible employees were included in the plan 1 1 Failure to test the basic da ta used by the actuary 1 No evidence of testing of participant data provided to the plan's actuary 1 No alternative procedures performed on non-reply participant confirmations No testing of employee withholdings for authorization 1 1 No evidence of work performed on individual participant accounts Detail tests of data samples incomplete 1 Inadequate work performed, most standard participant data 1 substantive audit proced ures not performed 1 No evidence of recalculation of employee deferra l percentage 1 No evidence of testing opening participant balances from plan inception to 12/31/2010 1 No testing for inclusiveness 1 No testing of health coverage /plan selected by participant 1 No recalculation of employee contributions 45

48 Plan Obligations Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Totals Strata Acceptable N/A Major Minor Minor 0 2 2 91 95 1-2 plans 0 5 1 1 5 83 95 3-5 plans 5 95 1 2 87 0 6-24 plans 3 2 1 53 65 6 25-99 plans 4 0 0 2 19 25 100-749 plans 25 1 1 0 1 22 750+ plans 23 4 3 Totals 15 355 400 Unacceptable, Major nefit Plan Audit Quality Center Membership in AIPCA Employee Be Strata No Totals Yes 1-2 plans 0 2 2 3-5 plans 1 4 5 6-24 plans 2 2 0 2 1 3 25-99 plans 100-749 plans 2 0 2 1 0 1 750+ plans 8 Totals 7 15 plan obligations and the number of The following details the unacceptab le major findings identified in occurrences. # Description of Unacceptable, Major Finding 7 No/insufficient testing of census da ta (defined benefit pension plans) 3 No work performed 1 No/inadequate testing of IBNR list's qualifications 2 Failure to assess specia Failure to test insu rance premiums paid 2 1 Failure to assess whether actuary used plan's provisions and considered amendment effective 1/1/2011 1 Failure to obtain liquidation basis actuarial report for the terminated plan 1 Failure to review/assess specialist's assumptions No evidence of testing 1 of plan's funding status 46

49 Parties In Interest/Prohibited Transactions Audit Quality Study Review Results Unacceptable, Acceptable, Unacceptable, Acceptable Strata Totals Major Minor Minor 32 18 8 37 95 1-2 plans 12 3-5 plans 32 95 44 7 41 20 14 20 95 6-24 plans 42 4 7 12 65 25-99 plans 20 4 0 25 1 100-749 plans 18 0 1 25 6 750+ plans 197 64 Totals 102 400 37 Unacceptable, Major Membership in AIPCA Employee Be nefit Plan Audit Quality Center Strata Yes No Totals 1-2 plans 4 33 37 3-5 plans 8 32 24 12 20 8 6-24 plans 25-99 plans 8 4 12 0 0 0 100-749 plans 1 0 1 750+ plans 33 69 Totals 102 The following details the unacceptab le major findings identified in parties in interest/prohibited transactions and the number of occurrences. # Description of Unacceptable, Major Finding 3 Audit performed by an "unlicensed" auditor 46 No work performed Failure to document related parties/parties in interest 39 29 Failure to document results of inquiries of management 17 Inadequate work 3 lose prohibited transactio ns in notes to financial Failure to properly disc statements 3 No/inadequate evidence of consid eration of effect of prohibited transactions/party in interest transactions on plan financial statements 3 Incomplete listing of parties in interest 2 No audit program 1 Failure to adequately and accurately identify accounting and reporting with parties in interest 47

50 No procedures performed to verify major areas regarding parties in 1 interest 1 Inadequate documentation of management inquiries 1 Inadequate work regarding transactions with plan sponsor of money going from plan to the sponsor 1 Inadequate work, overall conclusion of no non-exempt transactions ocedures performed and parties in was not supported by evidence of pr interest portion of audit program was not completed 48

51 Plan Tax Status Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Strata Totals Acceptable Minor Minor Major 51 10 10 24 1-2 plans 95 3-5 plans 9 6 20 95 60 68 10 5 12 95 6-24 plans 25-99 plans 56 2 5 2 65 100-749 plans 23 2 0 25 0 1 0 0 25 24 750+ plans Totals 282 32 28 58 400 Unacceptable, Major Membership in AIPCA Employee Be nefit Plan Audit Quality Center Strata Yes No Totals 0 24 24 1-2 plans 3-5 plans 14 20 6 11 1 6-24 plans 12 1 2 1 25-99 plans 0 0 0 100-749 plans 0 750+ plans 0 0 Totals 40 58 18 le major findings identified in plan tax status and the number of The following details the unacceptab occurrences. # Description of Unacceptable, Major Finding 3 Audit performed by an "unlicensed" auditor 27 No work performed 20 No evidence IRS tax compliance tests were reviewed 8 No tax determination letter obtained 7 Failure to document results of inquiries with management 4 Inadequate work No audit program 2 1 Compliance tests indicate data inte grity issues that could affect the results of the testing, but no in dication this was considered 1 Incorrect tax letter 1 Plan document is outdated 1 Footnotes do not match plan document 1 Footnotes do not address tax uncertainties 49

52 1 or which was for the correct plan IRS determination letter not reviewed 1 Inconsistent documentation regarding compliance tests No evidence of work performed in support of the prior year testing 1 in the current year return of excess results which resulted contributions 1 No evidence of IRS tax compliance tests 1 No work performed other than obtaining an IRS determination letter 1 Plan failed ADP & ACP testing wh ich required $48,257 in corrective distributions, but no evidence of work performed 50

53 Commitments & Contingencies Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Strata Totals Acceptable Minor Minor Major 65 1-2 plans 2 26 95 2 3-5 plans 65 11 4 15 95 6-24 plans 67 16 3 9 95 25-99 plans 2 1 3 64 58 100-749 plans 23 1 1 0 25 23 1 1 0 25 750+ plans Totals 301 33 12 53 399 Unacceptable, Major nefit Plan Audit Quality Center Membership in AIPCA Employee Be Yes No Totals Strata 1-2 plans 1 25 26 1 3-5 plans 15 14 8 1 9 6-24 plans 2 1 3 25-99 plans 0 0 0 100-749 plans 750+ plans 0 0 0 Totals 41 53 12 The following details the unacceptab le major findings identified in commitments & contingencies and the number of occurrences. # Description of Unacceptable, Major Finding 3 Audit performed by an "unlicensed" auditor 33 No work performed 12 Failure to document results of inquiries with management 8 Inadequate work 2 No audit program 51

54 Administrative Expenses Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Acceptable Strata Totals N/A Major Minor Minor 9 2 25 6 95 1-2 plans 53 7 6 18 10 95 54 3-5 plans 60 6-24 plans 2 18 6 95 9 25-99 plans 3 0 4 5 65 53 18 1 0 100-749 plans 2 25 4 1 0 0 1 25 23 750+ plans Totals 261 33 10 66 30 400 Unacceptable, Major Membership in AIPCA Employee Benefit Plan Audit Quality Center Strata No Totals Yes 2 23 25 1-2 plans 3 15 18 3-5 plans 10 6-24 plans 18 8 2 2 25-99 plans 4 100-749 plans 1 0 1 750+ plans 0 0 0 Totals 18 66 48 The following details the unacceptab le major findings identified in administrative expenses and the number of occurrences. # Description of Unacceptable, Major Finding 3 Audit performed by an "unlicensed" auditor 55 No work performed 7 Inadequate work performed 1 Area classified as immaterial bu t no other work or audit program 1 Expenses deemed immaterial but amount is above materiality threshold 1 Fees netted against forfeitures with negative fee reported as other income & not analyzed for possi ble related party transaction 52

55 Subsequent Events Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Totals Acceptable Strata Minor Minor Major 48 9 6 32 95 1-2 plans 55 2 26 95 12 3-5 plans 58 15 8 14 95 6-24 plans 65 54 4 4 3 25-99 plans 2 0 1 25 22 100-749 plans 23 2 0 0 25 750+ plans Totals 260 44 20 76 400 Unacceptable, Major Membership in AIPCA Employee Benefit Plan Audit Quality Center No Strata Yes Totals 2 30 32 1-2 plans 20 6 26 3-5 plans 5 14 9 6-24 plans 1 3 2 25-99 plans 1 0 1 100-749 plans 0 0 0 750+ plans 20 56 76 Totals The following details the unacceptab le major findings identified in subsequent events and the number of occurrences. Description of Unacceptable, Major Finding # 3 Audit performed by an "unlicensed" auditor 42 No work performed Failure to review interim financial information 14 13 Failure to document results of inquiries with management 9 Inadequate work performed 2 No audit program for this area of audit 2 Inadequate documentation of inquiries 2 Inadequate audit evidence that work was performed 1 Inadequate documentation - unable to determine accounting records or data reviewed, with whom inquir ies were made, and result of such inquiries mplete liquidation of the plan by 1 Failure to obtain evidence of co 7/25/12 53

56 1 Audit documentation did not indicate subsequent event of plan asset transfer to a successor plan in 2012 1 No review of subsequent plan amendments 1 No indication whether receivab les were subsequently received 1 final 5500 filing in which benefits Inadequate review through 10/1/12 of paid were materially greater that the accumulated benefit obligation reflected on the 12/31/11 statement of accumulated plan benefits 1 No inquiries of plan administrator or trustee, inquiries were only made of controller who was not a plan official pertained to the 2010 plan year 1 Audit documentation submitted 54

57 Plan Mergers & Terminating Plans Audit Quality Study Review Results Acceptable Unacceptable, Unacceptable, Acceptable, N/A Totals Strata Minor Minor Major 0 1-2 plans 0 89 95 6 0 2 0 0 1 92 95 3-5 plans 2 0 0 1 92 95 6-24 plans 3 0 0 62 65 25-99 plans 0 1 0 1 22 25 100-749 plans 1 2 1 0 0 22 25 750+ plans 3 2 0 16 379 400 Totals Unacceptable, Major Membership in AIPCA Employee Benefit Plan Audit Quality Center Yes No Totals Strata 0 0 0 1-2 plans 1 0 1 3-5 plans 0 1 6-24 plans 1 25-99 plans 0 0 0 1 100-749 plans 1 0 750+ plans 0 0 0 Totals 2 1 3 The following details the unacceptab plan mergers & terminating plans le major findings identified in and the number of occurrences. # Description of Unacceptable, Major Finding 1 Failure to obtain liquidat ion basis actuarial report 1 er contribution on liquidation basis Failure to evaluate potential employ 1 Failure to perform audit procedures on plan liquidation occurring during subsequent events time period 1 Inadequate documentation of audit work on subsequent events/pending dissolution of the plan 1 Failure to test plan assets transf erred at 12/31/2011 (plan year end) to participant level until 2013 another plan at the detailed 55

58 Plan Representations Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Strata Totals Acceptable Minor Minor Major 77 4 6 8 1-2 plans 95 3-5 plans 4 2 6 95 83 84 7 4 0 95 6-24 plans 65 59 4 0 2 25-99 plans 2 0 0 25 23 100-749 plans 21 4 0 0 25 750+ plans Totals 347 25 12 16 400 Unacceptable, Major Membership in AIPCA Employee Benefit Plan Audit Quality Center Strata Yes No Totals 1-2 plans 1 8 7 3-5 plans 2 4 6 0 0 6-24 plans 0 1 2 25-99 plans 1 0 0 0 100-749 plans 0 0 0 750+ plans 4 16 12 Totals able major findings identified in plan representations and the The following details the unaccept number of occurrences. # Description of Unacceptable, Major Finding 3 Audit performed by an "unlicensed" auditor No audit performed, auditor perfor med and issued a "review" report 1 4 No client representation letter obtained 6 Inadequate represen tations obtained 5 Client representations were not appropriately tailored to the plan 2 Inappropriate client representation letter date 1 Unsigned client representation letter 1 Failure to evaluate numerous representations that were inconsistent with information known by the auditor 1 Client representation letter was not on letterhead of the plan or plan sponsor & the signer was identified as "office ma nager". Signer also signed as the plan admini strator on the Form 5500. language for a full scope audit but a 1 Representation letter contains the limited scope audit was performed 56

59 Compliance with GAAS & GAAP Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Strata Totals Acceptable Minor Minor Major 39 12 9 35 1-2 plans 95 3-5 plans 5 6 27 95 57 61 11 6 17 95 6-24 plans 25-99 plans 49 5 6 5 65 100-749 plans 22 0 0 25 3 750+ plans 4 0 0 25 21 Totals 249 40 27 84 400 Unacceptable, Major Membership in AIPCA Employee Benefit Plan Audit Quality Center Strata Yes No Totals 31 35 4 1-2 plans 22 27 5 3-5 plans 10 7 17 6-24 plans 0 5 5 25-99 plans 0 0 0 100-749 plans 0 0 0 750+ plans 24 60 84 Totals le major findings of establishe d professional standards (GAAS & The following details the unacceptab GAAP) in audit reports issued and th e number of occu rrences. # Description of Unacceptable, Major Finding 3 Audit performed by an "unlicensed" auditor No audit performed, auditor perfor med and issued a "review" report 1 57 Inadequate footno te disclosures 28 Inappropriate presentation of fi nancial information on financial statements 16 No/lack of ASC 820 Fair Va lue Measurement disclosures 4 Report not modified for lack of ERISA schedules 3 Incorrect/incomplete ASC 820 Fair Value Measurement disclosures 4 Opinion does not extend to all financial statemen ts and/or years presented 4 Failure to refer to supplemental information (e.g., ERISA required schedules) 2 Delinquent employee contributions not reported/disclosed of participant loans 2 Inappropriate presentation 57

60 2 No adjustment from fa value for fully-benefit ir value to contract responsive contract 2 Audit opinion does not contain the appropriate language required by SAS 58 (e.g., reference to U.S. GAAP) 2 No FAS 157 Subsequent Events disclosure Plan failed to present its financial 1 statements on the liquidation basis of accounting and the auditor failed to evaluate and/or report on this departure from GAAP 1 Audit report does not contain the "independent" title 1 Audit workpapers did not document sufficient appropriate audit evidence to support an unqualified opinion Failure to modify full scope, unquali fied report for a material omission 1 from the schedule of reportable transactions 1 Failure to present benefit responsi ve insurance contract at contract value and to make necess ary footnote disclosures 1 Improper reporting in auditor's report of benefit responsive and non- benefit-responsive contracts 1 Incorrect footnote disclosures 1 Opinion only, no financial statements attached to 5500 1 Required 5% investment e incorrect plan year disclosure is for th Inappropriately presented benefit pa 1 yments as refunds of contributions Inadequate footnote di sclosure for investments 1 1 Inappropriate report date Investment amount on financial statements not consistent with 1 footnote disclosures 1 Incomplete schedule of assets 1 Limited scope audit inappropriately applied 1 Reportable transaction schedule presented but should not have one 1 Principal IPG contract of $4.5 million excluded from the plan's financial statements 1 Lack of consideration of report modification for significant uncertainty for rehabilitation of plan to avoid insolvency 1 Financial statements inappropriat ely presented on the liquidation basis, liquidation basis does not apply to frozen plans 1 No reference to the other comprehensive basis of accounting used in the auditor's report Inappropriately indicated limited scope covered benefit payments 1 58

61 Compliance with Department of Labor Rules and Regulations For Reporting and Disclosure Audit Quality Study Review Results Acceptable, Unacceptable, Unacceptable, Acceptable Totals Strata Minor Major Minor 1-2 plans 8 5 49 95 33 3-5 plans 4 16 95 72 3 6-24 plans 3 4 13 95 75 25-99 plans 55 2 5 65 3 100-749 plans 25 0 0 25 0 750+ plans 23 2 0 0 25 Totals 19 15 67 299 400 Unacceptable, Major Membership in AIPCA Employee Benefit Plan Audit Quality Center Yes Strata No Totals 1-2 plans 2 33 31 3-5 plans 3 13 16 6-24 plans 5 13 8 25-99 plans 3 2 5 100-749 plans 0 0 0 750+ plans 0 0 0 16 51 67 Totals The following details the unacceptab le major findings in audit report s issued related to compliance with Department of Labor Rules and Regulations for Reporting and Disclosure and the number of occurrences. Description of Unacceptable, Major Finding # Audit performed by an "unlicensed" auditor 3 1 No audit performed, auditor perfor med and issued a "review" report 1 Audit performed by an auditor who lacked independence 11 No/inadequate footno te disclosures 11 Required supplemental sche dules not prepared/attached 9 Incomplete Schedule of Assets He ld for Investment (e.g., does not include all investments, missing part icipant loans, no indication of parties in interest, etc.) 8 Unsigned audit report 7 Delinquent employee contributions not reported/disclosed No/Incomplete audit report atta ched to the plan's Form 5500 6 59

62 5 Financial statements do no t agree to the Schedule H Schedule H, Line 3, audit opin 4 ion type not properly completed 4 Limited scope audit incorrectly applied Statement of Net Assets not presented comparatively 3 Audit report contains an unacceptable qualification 1 1 Administrative fees not separately disclosed from benefit payments 1 Certification provided by third-party not supported by evidence of Agency relationship with trustee 1 A's for welfare benefits but no Plan Form 5500 contained Schedule evidence of review to determine whether a separate plan & filing should have been made 1 Incorrect format of schedule of assets 1 No certification to support limite d scope audit disclaimer opinion in the audit report 1 Inappropriate reference to certifying entity Opinion does not extend to all 1 required supplemental schedules 1 Reference made to an incorrect, non- qualifying, certifying entity in the audit opinion 1 ions did not disclose common stock Schedule of Reportable Transact shares purchased from office rs of the sponsor company 1 vestment does not break out self- Schedule of Assets Held for In directed brokerage accounts 1 Total investments per schedule of assets does not reconcile to total assets presented on the pl an's financial statements 1 the schedule of assets held Inappropriate items included on 1 Incorrect schedule of assets held 1 Auditor unable to ex plain $21,530 in deemed distribution loans, principal and interest 1 Audit report is not for the plan 60

63 Appendix III Appendix III Overview strata, the number of audits with an unacceptable major review The following chart presents, among result, by the number of affected audit areas. For example, in the 1-2 plan stratum, there were 2 audits with an unacceptable major review result with one affected audit area. The remainder of Appendix III provides the detail findings of the 234 unacceptable major review result. audits with an Number of Audits by Stratum by Number of Deficient Areas of Audit for Engagements With an Unacceptable Major Review Result Strata 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Total 7 2 5 7 3 7 2 5 8 3 6 4 4 5 72 4 1 - 2 plans 7 3 7 8 11 3 2 1 7 3 6 2 4 0 1 65 3 - 5 plans 7 64 7 9 4 2 5 8 2 9 4 4 3 0 0 0 6 - 24 plans 1 1 4 6 6 0 3 2 2 2 0 0 0 0 0 27 25 - 99 plans 3 1 0 0 1 0 0 0 1 0 0 0 0 0 0 0 100 - 749 plans 3 1 1 0 0 1 0 0 0 0 0 0 0 0 0 0 750+ plans 234 16 22 23 27 30 14 14 6 17 16 12 8 10 4 15 Totals 1.7% 4.3% 100% 3.4% 2.6% 6.8% 9.4% 9.8% 11.5% 12.8% 6.0% 6.0% 6.4% 7.3% 6.8% 5.1% 61

64 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Audit Area(s) Detail of Findings Type Findings Member Scope No 15 Limited DC 401(k) Internal No/inadequate documentation of internal 1 Controls control environment Lack of documentation of risk assessment procedures No/inadequate evidence of fraud "brainstorming" No review of internal control of service provider(s) No/inadequate testing of compliance with Notes Receivable plan document No test of timely remittance of employee Contributions contributions Received & Receivable No testing of compliance with compensation provisions Inadequate testing of use of forfeitures Inadequate documentation of recalculation of contributions No/inadequate work regarding eligibility of Benefit Payments individuals receiving benefits No recalculation of benefit payments Participant No/insufficient testing of payroll data Data & Inadequate testing of participant Participant eligibility/terminations/forfeitures Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No documentation of parties in Parties in interest/related parties Interest/ Prohibited No documentation of results of inquiries Transactions with management Plan Tax Status No evidence IRS tax compliance tests were reviewed No documentation of results of inquiries with management 62

65 1-2 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Scope Findings Member Type Commitments & No documentation of results of inquiries Contingencies with management Subsequent No review of interim financial data Events No documentation of results of inquiries with management Minor Item(s): No evidence of required communications Planning & (114/115) Supervision Audit report dated under old standards when substantial audit work was completed rather than under the new standards of when work had been reviewed Uncertified investments/transactions not Investments & Investment audited Transactions No agreement of certified investment income to financial statements Administrative No work performed Expenses Plan Inadequate representations Representations Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inadequate footnote disclosures t attached/prepared Compliance with Required schedules no ERISA & DOL Rules No 15 Limited DC 401(k) All relevant areas Unlicensed auditor 2 of audit Compliance with Unlicensed auditor GAAS & GAAP Unlicensed auditor Compliance with ERISA & DOL Rules 63

66 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type No Planning & Full DC 15 No/lack of lack of evidence of audit 3 Supervision planning No/insufficient audit program Improper performance of limited scope audit No/inadequate assessment of fraud risk Internal Controls No work performed Investments & No work performed Investment Audit workpapers did not contain the Transactions certification for a limited scope audit Notes Receivable No work performed No work performed Contributions Received & Receivable Benefit Payments No work performed No work performed Participant Data & Participant Accounts Parties in No work performed Interest/Prohibited Transactions Plan Tax Status No work performed Commitments & No work performed Contingencies Administrative No work performed Expenses No work performed Subsequent Events Plan No plan representation letter Representations Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Report does not refer to prior year presented Limited scope audit incorrectly applied Compliance with ERISA & DOL Rules Financial statements did not agree to Form 5500, Schedule H Schedule H, Line 3, opinion type incorrectly indicated 64

67 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Type Scope Findings Member No DC 401(k) Limited 15 Internal Controls No/inadequate documentation of 4 internal control environment Lack of documentation of risk assessment procedures No/inadequate evidence of fraud "brainstorming" No review of internal control of service provider(s) Notes Receivable No/inadequate testing of compliance with plan document Contributions No test of timely remittance of Received & employee contributions No testing of compliance with Receivable compensation provisions Inadequate testing of use of forfeitures Inadequate documentation of recalculation of contributions No/inadequate work regarding Benefit Payments eligibility of individuals receiving benefits No recalculation of benefit payments Participant Data & No/insufficient testing of payroll data Inadequate testing of participant Participant Accounts eligibility/terminations/forfeitures Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No documentation of parties in Parties in interest/related parties Interest/Prohibited No documentation of results of Transactions inquiries with management No evidence IRS tax compliance tests Plan Tax Status were reviewed No documentation of results of inquiries with management No documentation of results of Commitments & Contingencies inquiries with management Subsequent Events No review of interim financial data No documentation of results of inquiries with management 65

68 1-2 Plan Stratum EBPAQC Audit Plan # of Audit Area(s) Detail of Findings Review # Scope Findings Member Type No evidence of required communications Minor Item(s): (114/115) Planning & Audit report dated under old standards Supervision when substantial audit work was completed rather than under the new standards of when work had been reviewed Uncertified investments/transactions not Investments & Investment audited No agreement of certified investment Transactions income to financial statements Administrative No work performed Expenses Inadequate representations Plan Representations Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Inadequate footnote disclosures Compliance with Required schedules not attached/prepared ERISA & DOL Rules No 15 Full DC 401(k) All relevant areas Unlicensed auditor 5 of audit Compliance with Unlicensed auditor GAAS & GAAP Compliance with Unlicensed auditor ERISA & DOL Rules Yes 14 Limited DC 403b Planning & No/insufficient audit program 6 Supervision Lack of documentation of risk assessment Internal Controls procedures No assessment/documentation of control risk No SOC1 report bridge letter Investments & No audit program for this area of audit Investment Transactions No work performed Notes Receivable No audit program for this area of audit 66

69 1-2 Plan Stratum Plan Audit # of EBPAQC Review # Audit Area(s) Detail of Findings Scope Findings Member Type Contributions No recalculation of employer and/or employee contributions Received & Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions Inadequate testing of use of forfeitures Benefit Payments No work performed Participant Data & Inadequate testing of participant Participant eligibility/terminations/forfeitures Inadequate testing of allocations to Accounts participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets No work performed Parties in Interest/Prohibited Transactions No work performed Commitments & Contingencies Administrative No work performed Expenses Subsequent Events Inadequate work - documentation submitted pertained to the 2010 plan year Inadequate representations Plan Representations Representation letter inappropriately contains wording for a full scope audit Inadequate footnote disclosures Compliance with GAAS & GAAP Compliance with Incorrect format for schedule of assets ERISA & DOL Rules Unlicensed auditor No 14 Limited DC All relevant areas 7 of audit Compliance with Unlicensed auditor GAAS & GAAP Compliance with Unlicensed auditor ERISA & DOL Rules 67

70 1-2 Plan Stratum EBPAQC Audit Plan # of Audit Area(s) Detail of Findings Review # Member Scope Findings Type No Full DC Planning & No/lack of evidence of audit planning 14 8 Supervision Internal Controls No work performed Investments & No work performed Investment Transactions Notes Receivable No work performed No work performed Contributions Received & Receivable Benefit Payments No work performed No work performed Participant Data & Participant Accounts Parties in No work performed Interest/Prohibited Incomplete identification of parties in Transactions interest/related parties No work performed Plan Tax Status Commitments & No work performed Contingencies No work performed Administrative Expenses Subsequent Events No work performed Inadequate footnote disclosures Compliance with GAAS & GAAP Non-compliance with SAS 58 - no reference to U.S. GAAP and GAAS Statement of net assets not Compliance with ERISA & DOL Rules comparative IQPA opinion contains an unacceptable qualification Schedule of investments does not break out self -directed brokerage accounts Schedule H, Line 3, opinion type incorrectly indicated 68

71 1-2 Plan Stratum EBPAQC # of Plan Audit Review # Detail of Findings Audit Area(s) Findings Type Member Scope 9 14 Limited DC 401(k) Planning & No/insufficient review of plan No documents/plan operations Supervision No evidence of planning inquiries No analytical procedures Internal Controls No/inadequate documentation of internal control environment No evidence of SOC1 report review reliance No review of internal control of service provider(s) No documentation to support assessment of control risk below maximum Fraud brainstorming did not include in- charge who performed most of the audit work Investments & Audit workpapers did not contain the Investment certification Transactions The trust report prepared by and obtained from the recordkeeper No/inadequate testing of compliance with Notes Receivable plan document Contributions No testing of rollover contributions Received & which were material Receivable No/inadequate work regarding eligibility of individuals receiving benefits No recalculation of benefit payments Benefit Payments No/inadequate work regarding forfeitures No testing to ensure participant receipt of distribution No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of participant eligibility/ terminations/ forfeitures Accounts No testing of compliance with compensation provisions No reconciliation of participant accounts to total assets No evidence IRS tax compliance tests Plan Tax Status were reviewed No documentation of results of inquiries with management Commitments & Inadequate evidence that work was Contingencies performed 69

72 1-2 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Administrative No work performed Expenses Subsequent Events Inadequate evidence that work was performed Compliance with No/lack of ASC 820 fair value GAAS & GAAP measurement disclosures Inadequate footnote disclosures Compliance with No/inadequate footnote disclosures ERISA & DOL Rules Three representations in the template Minor Item(s): Plan were omitted from the client signed Representations representation letter, but there was no documentation of any follow up by the IQPA 10 No 13 Full DC 403b Planning & No/insufficient audit program Supervision No evidence of required communications (114/115) No documentation of evaluation of Internal Controls internal control No assessment/documentation of control risk No evidence of SOC1 report review reliance Investments & No work performed Investment Transactions Contributions No recalculation of employer and/or Received & employee contributions Receivable No test of timely remittance of employee contributions No tracing of benefit payments to Benefit Payments participant accounts Participant Data & Inadequate testing of allocations to participant accounts Participant Inadequate testing of participant Accounts investment options Parties in No work performed Interest/Prohibited Transactions Plan Tax Status No work performed Commitments & No work performed Contingencies 70

73 1-2 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Administrative No work performed Expenses Subsequent Events No work performed Compliance with No/lack of ASC 820 fair value measurement disclosures GAAS & GAAP Report not modified for lack of ERISA schedules Compliance with No/inadequate footnote disclosures t attached/prepared Required schedules no ERISA & DOL Rules No/lack of lack of evidence of audit No 13 Full DC Planning & 11 401(k) planning Supervision No/insufficient audit program No work performed Internal Controls No work performed Investments & Investment Transactions Contributions No work performed Received & Receivable Benefit Payments No work performed Participant Data & No work performed Participant Accounts Parties in No work performed Interest/Prohibited Transactions Plan Tax Status No work performed Commitments & No work performed Contingencies Subsequent Events No work performed Plan Inadequate representations Representations Representations not appropriately tailored to plan 71

74 1-2 Plan Stratum EBPAQC # of Audit Plan Detail of Findings Review # Audit Area(s) Scope Member Type Findings Compliance with Inadequate footnote disclosures Report did not refer to supplemental GAAS & GAAP information Inappropriately presented benefit payments as refunds of contributions Compliance with Incomplete schedule of assets ERISA & DOL Rules No/insufficient audit program No Full Health Planning & 13 12 No/insufficient review of plan Supervision documents/plan operations No evidence of required communications (114/115) No/inadequate assessment of fraud risk Internal Controls No/inadequate documentation of internal control environment Lack of documentation of risk assessment procedures No/inadequate evidence of fraud inquiries Investments & No testing of end of year asset values Investment No testing of investment transactions Insufficient work performed Transactions Insufficient work performed of Contributions contributing employers (multi-employer Received & plans) Receivable No test of timely remittance of employee contributions Benefit Payments No work performed Participant Data No work performed No work performed Plan Obligations Parties in No documentation of parties in interest/related parties Interest/Prohibited Transactions No documentation of results of inquiries with management No evidence IRS tax compliance tests Plan Tax Status were reviewed Administrative No work performed Expenses Subsequent Events No review of interim financial data 72

75 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Type Scope Findings Member Compliance with Opinion only, no financial statements attached to 5500 GAAS & GAAP Compliance with Opinion only, no financial statements ERISA & DOL Rules attached to 5500 No 13 Other No audit performed DC 13 All relevant areas of audit "Review" Compliance with No audit performed GAAS & GAAP Compliance with No audit performed ERISA & DOL Rules No 12 Limited 14 Planning & No/lack of evidence of audit planning DC 401(k) Supervision No evidence of required communications (114/115) No/insufficient review of plan documents/operation No assessment/documentation of control Internal Controls risk No/inadequate evidence of fraud "brainstorming" No/inadequate evidence of fraud inquiries No evidence of SOC1 report review reliance Notes Receivable No work performed No work performed Contributions Received & Receivable Benefit Payments No work performed No/insufficient testing of payroll data No Participant Data & Participant testing of compliance with compensation provisions Accounts Inadequate testing of allocations to participant accounts Inappropriate reliance on SOC1 report No work performed Parties in Interest/Prohibited No documentation of parties in interest/related parties Transactions Commitments & No work performed Contingencies 73

76 1-2 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Administrative No work performed Expenses Subsequent Events No work performed Compliance with No/inadequate footnote disclosures ERISA & DOL Rules Incomplete schedule of assets No tax determination letter obtained Minor Item(s): Plan Tax Status No 12 15 DC 401(k) Investments & Certifying entity identified in report was Limited Investment not consistent with certification Certification did not have financial Transactions information attached Benefit Payments No recalculation of benefit payments No/inadequate work regarding eligibility No test of receipt of benefit payments Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of participant eligibility/ terminations/forfeitures Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Parties in Inadequate work Interest/Prohibited Identification of a related party as a trustee who does not appear to be a Transactions trustee Subsequent Events No review of interim financial data No documentation of results of inquiries with management Inadequate footnote disclosures Compliance with GAAS & GAAP Report not modified for lack of ERISA schedules Compliance with Required schedules not ERISA & DOL Rules attached/prepared Engagement letter contains full scope Minor I em(s): t language for limited scope audit Planning & Expectations memo identified significant Supervision changes - one identified & one was not, both were not addressed 74

77 1-2 Plan Stratum Audit Plan EBPAQC # of Audit Area(s) Detail of Findings Review # Member Scope Findings Type Internal Controls No/inadequate documentation of internal control environment No documentation of evaluation of internal control Control risk assessed at low for all areas was not supported Contributions No recalculation of employer and/or Received & employee contributions No testing of compliance with Receivable compensation provisions Inadequate testing of use of forfeitures Plan Tax Status No evidence IRS tax compliance tests were reviewed Plan Representations not appropriately Representations tailored to plan No audit materiality determined Planning & No 12 Limited DC 401(k) 16 Supervision No indication of supervisory review of workpapers No/inadequate documentation of internal Internal Controls control environment No documentation of evaluation of internal control No/inadequate evidence of fraud "brainstorming" Investments & Audit workpapers did not contain the certification Investment Transactions Contributions No test of timely remittance of Received & employee contributions Receivable No recalculation of benefit payments Benefit Payments Participant Data & No/insufficient testing of payroll data Inadequate testing of allocations to Participant Accounts participant accounts No work performed Parties in Interest/Prohibited Transactions Plan Tax Status No work performed No work performed Commitments & Contingencies 75

78 1-2 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Member Findings Type Subsequent Events No work performed Compliance with No/lack of ASC 820 fair value GAAS & GAAP measurement disclosures Compliance with Financial statements did not agree to ERISA & DOL Rules Schedule H No Planning & Limited DC 401(k) No/lack of evidence of audit planning 12 17 No/insufficient audit program Supervision No/inadequate assessment of fraud risk No/insufficient review of plan documents/operations No work performed Internal Controls No/inadequate documentation of internal control environment No assessment/documentation of control risk No/inadequate evidence of fraud "brainstorming" Investments & No list of plan investments Investment Transactions Notes Receivable No work performed Contributions No recalculation of employer and/or employee contributions Received & Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions Inadequate testing of use of forfeitures Benefit Payments No work performed No work performed Participant Data & Participant Accounts Parties in No work performed Interest/Prohibited Transactions No work performed Plan Tax Status 76

79 1-2 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member Commitments & Inadequate work Contingencies Administrative No work performed Expenses Subsequent Events No work performed No 12 Full DC Investments & No testing of investment transactions 18 Investments per the financial statements Investment Transactions did not agree to the confirmation trust statement Notes Receivable No/inadequate testing of compliance with plan document Contributions No recalculation of employer and/or employee contributions Received & Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions No/inadequate work regarding eligibility Benefit Payments of individuals receiving benefits No recalculation of benefit payments Inadequate testing of participant Participant Data & Participant eligibility/terminations/forfeitures No/insufficient testing of payroll data Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Parties in No documentation of results of inquiries Interest/Prohibited with management Transactions Commitments & Inadequate work Contingencies Administrative No work performed Expenses No work performed Subsequent Events Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Inadequate footnote disclosures Delinquent employee contributions not Compliance with reported/disclosed ERISA & DOL Rules 77

80 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Type Scope Findings Member No/inadequate documentation of Minor Item(s): internal control environment Internal Controls Planning & 12 Limited DC 401(k) No No/lack of evidence of audit planning 19 Supervision No/insufficient audit program No/inadequate assessment of fraud risk No/insufficient review of plan documents/operations Internal Controls No work performed No work performed Contributions Received & Receivable Benefit Payments No work performed Participant Data & No work performed Participant Accounts No work performed Parties in Interest/Prohibited Transactions Plan Tax Status No work performed Commitments & No work performed Contingencies Administrative No work performed Expenses Subsequent Events No work performed Inadequate footnote disclosures Compliance with GAAS & GAAP Compliance with No/inadequate footnote disclosures ERISA & DOL Rules Auditor lacked independence No 11 Limited DC 401(k) Planning & 20 Supervision No/lack of evidence of audit planning No/insufficient audit program No evidence of required communications (114/115) No/inadequate evidence of fraud Internal Controls "brainstorming" No evidence of SOC1 report review reliance 78

81 1-2 Plan Stratum # of Audit EBPAQC Plan Review # Audit Area(s) Detail of Findings Scope Findings Member Type Investments & No audit program for this area of audit Investment Transactions Notes Receivable No work performed No audit program for this area of audit Contributions No work performed No audit program for this area of audit Received & Receivable Benefit Payments No work performed No audit program for this area of audit No work performed Participant Data & Participant No audit program for this area of audit Accounts Parties in No work performed No audit program for this area of audit Interest/Prohibited Transactions No identification of parties in interest/related parties Plan Tax Status No work performed No audit program for this area of audit No work performed Commitments & Contingencies No audit program for this area of audit No work performed Subsequent Events No audit program for this area of audit DC 401(k) No/insufficient review of plan No 11 Limited Planning & 21 Supervision documents/operations No/inadequate procedures on initial/beginning balances No/inadequate work related to predecessor auditors No/inadequate documentation of internal Internal Controls control environment Lack of documentation of risk assessment procedures Inconsistent evidence of review of SOC1 report Certification not consistent with plan Investments & Investment reporting period Transactions Inadequate testing of change in service provider Uncertified investments and/or transactions not audited 79

82 1-2 Plan Stratum # of EBPAQC Audit Plan Review # Audit Area(s) Detail of Findings Type Scope Findings Member Notes Receivable No/inadequate testing of compliance with plan document Participant loans were not certified and full scope procedures were not performed No schedule of loans reconciling to financial statements Insufficient work to determine if total amount was proper Contributions No recalculation of employer and/or Received & employee contributions Receivable Inadequate testing of use of forfeitures No contributions withheld from a bonus and no testing to determine the propriety of such No/inadequate work regarding eligibility Benefit Payments of individuals receiving benefits Inadequate testing of participant Participant Data & Participant eligibility/terminations/forfeitures Inadequate testing of allocations to Accounts participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets Inadequate work Parties in Interest/Prohibited No documentation of parties in Transactions interest/related parties No documentation of results of inquiries Plan Tax Status with management No tax determination letter obtained No evidence IRS tax compliance tests were reviewed Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Inadequate footnote disclosures Compliance with Required schedules no t attached/prepared Statement of net assets not comparative ERISA & DOL Rules 80

83 1-2 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Member Findings Type No Limited DC 401(k) Planning & No/insufficient review of plan 11 22 Supervision documents/operations No/inadequate work related to predecessor auditors No evidence of required communications (114/115) Firm is not licensed but individual is licensed Internal Controls No evidence of SOC1 report review reliance Inconsistency in risk assessment for contributions Notes Receivable No/inadequate testing of compliance with plan document Insufficient documentation to enable re- Contributions performance Received & Receivable Insufficient work related to possible late submission of employee contributions No/inadequate work regarding eligibility Benefit Payments of individuals receiving benefits No/inadequate testing of hardship/in- service payments Un-reconciled difference in total benefit payments between distribution listing and that reported on the financial statements No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of participant eligibility/ terminations/forfeitures Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Expenses deemed immaterial but amount Administrative Expenses is above materiality threshold Fees netted against forfeitures with negative fee reported as other income & not analyzed for possible related party transaction No review of interim financial data Subsequent Events No documentation of results of inquiries with management 81

84 1-2 Plan Stratum EBPAQC # of Plan Audit Review # Detail of Findings Audit Area(s) Findings Type Member Scope No disclosure of prohibited transactions Minor Item(s): in notes to financial statements Parties in Inadequate work Interest/Prohibited Transactions Commitments & No documentation of results of inquiries Contingencies with management Inadequate work Compliance with Inadequate footnote disclosures Delinquent employee contributions not GAAS & GAAP reported/disclosed No work performed No 10 Limited DC 401(k) Notes Receivable 23 No resolution of variances in calculations Contributions Received & Lack of documentation for support of Receivable employer contribution formula Lack of identification of improper use of forfeitures to offset employer contribution prior to plan expenses being paid No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of participant eligibility/terminations/forfeitures Accounts No/insufficient testing of payroll data Parties in No disclosure of prohibited transactions in notes to financial statements Interest/Prohibited Transactions Inadequate work No/lack of ASC 820 fair value Compliance with GAAS & GAAP measurement disclosures Inadequate footnote disclosures Compliance with Limited scope audit incorrectly applied t attached/prepared Required schedules no ERISA & DOL Rules Lack of documentation of risk assessment Minor Item(s): procedures Internal Controls No/inadequate evidence of fraud "brainstorming" No review of internal control of service provider(s) 82

85 1-2 Plan Stratum EBPAQC # of Audit Plan Detail of Findings Review # Audit Area(s) Type Member Findings Scope Investments & 3 of 4 insurance policies were not available and no documentation Investment Transactions supporting estimated value of the cash surrender value of the policies No/inadequate work regarding eligibility Benefit Payments of individuals receiving benefits Lack of follow-up on inconsistencies in reporting of distributions to participants who appear to be related parties Subsequent Events No documentation evidencing what subsequent accounting records were reviewed and the results of examinations No 10 Full DC 401(k) Internal Controls No/inadequate documentation of internal 24 control environment No evidence of SOC1 report review reliance Lack of evidence to support reduction in control risk Investments & No assessment of valuation specialist's Investment qualifications Transactions No testing of investment transactions No testing of investment income Inadequate testing of change in service provider Inadequate identification of plan's investment medium(s) at end of year Participant Data & Inadequate testing of change in service provider Participant Accounts Plan Tax Status No work performed Plan Representations not appropriately Representations tailored to plan Inappropriate representation letter date No/lack of ASC 820 fair value Compliance with GAAS & GAAP measurement disclosures Inadequate footnote disclosures Compliance with Required schedules not ERISA & DOL Rules attached/prepared Incorrect schedule of assets held for investment 83

86 1-2 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Scope Findings Member Type Lack of planning analytical procedures Minor Items: Planning & Supervision No reconciliation of employer & Contributions employee contribution amounts Received & Receivable Benefit Payments No reconciliation of distributions No documentation of evaluation of Internal Controls No 10 Full DC 401(k) 25 internal control No assessment/documentation of control risk No confirmation of investments Investments & Investment No testing of investment transactions Transactions No work performed Benefit Payments Participant Data & No/insufficient testing of payroll data Participant No testing of compliance with Accounts compensation provisions Inadequate testing of allocations to participant accounts Parties in No work performed Incomplete list of parties in interest Interest/Prohibited Transactions Commitments & No work performed Contingencies No work performed Subsequent Events Compliance with Opinion does not extend to all financial GAAS & GAAP statements Inadequate footnote disclosures No analytics Minor Item(s): No evidence of supervisory review Planning & Supervision Incorrect opinion disclosed on Schedule Compliance with ERISA & DOL Rules H, Part III 84

87 1-2 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Member Findings Type No 10 Limited DC 401(k) Contributions No testing of compliance with 26 Received & compensation provisions Receivable Inadequate work recalculating employer and employee contributions Circular employee contribution testing Eligibility testing did not include test of end of year employment requirement Inadequate follow up on errors noted in Benefit Payments benefit recalculation testing No testing of participant receipt Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of Accounts eligibility/terminations/forfeitures Inadequate testing of participant investment options No reconciliation of total participant accounts to total assets Report dated prior to partner review sign Minor Item(s): off date Planning & Management letter dated for date prior Supervision to sponsor signature date No/inadequate evidence of fraud Internal Controls inquiries No/inadequate documentation of internal control environment No evidence of SOC1 report review reliance Control risk below maximum but no evidence of test of controls No evidence IRS tax compliance tests Plan Tax Status were reviewed Unclear if determination letter was for the plan Eligibility period for pretax and rollover contributions was waived but there were no amendments to support this Subsequent Events No review interim financial data Plan Inappropriate representation letter date Representations Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inadequate footnote disclosures 85

88 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Type Member Compliance with No/inadequate footnote disclosures ERISA & DOL Rules No 10 Health Planning & No/insufficient review of plan Full 27 Supervision documents/plan operations No review of internal control of service Internal Controls providers Contributions No recalculation of employer and/or Received & employee contributions No test of timely remittance of employee Receivable contributions No/inadequate work regarding eligibility Benefit Payments of individuals receiving benefits No/inadequate work regarding validity of claims No recalculation of benefit payments No work performed Participant Data Inadequate testing of participant eligibility/terminations/forfeitures Plan Obligations No work performed Administrative No work performed Expenses Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inadequate footnote disclosures Compliance with No/inadequate footnote disclosures ERISA & DOL Rules No documentation of pa rties in Minor Item(s): interest/related parties Parties in Interest/Prohibited Transactions No/insufficient review of plan Planning & No 10 Full DC 401(k) 28 documents/plan operations Supervision Lack of preliminary analytics No/inadequate documentation of internal Internal Controls control environment No assessment/documentation of control risk Lack of documentation of risk assessment procedures No evidence of SOC1 report review reliance SOC1 report does not cover entire period and no work performed to address such 86

89 1-2 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Scope Findings Member Type Investments & No testing of end of year asset values No testing of investment transactions Investment Transactions No testing of investment income No recalculation of employer and/or Contributions employee contributions Received & Receivable No test of timely remittance of employee contributions Participant Data & No work performed Participant Accounts No work performed Parties in Interest/Prohibited Transactions No work performed Commitments & Contingencies No work performed Subsequent Events Compliance with Inadequate footnote disclosures GAAS & GAAP Compliance with Statement of net assets not comparative ERISA & DOL Rules No planning analytics No 10 Limited DC 401(k) Planning & 29 Supervision Internal Controls No documentation of evaluation of internal control No assessment/documentation of control risk No/inadequate evidence of fraud "brainstorming Contributions No test of timely remittance of employee contributions Received & Receivable No testing of compliance with compensation provisions No test of rollovers No reconciliation to trust report and sponsor records Inadequate testing of forfeitures Inadequate work Benefit Payments No list of benefit payments made No reconciliation to trust and participant accounts No test of corrective distributions No review of supporting documents & approvals No tracing of payment to participant's account 87

90 1-2 Plan Stratum EBPAQC Audit # of Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type No/insufficient testing of payroll data Participant Data & No evidence of work performed on Participant Accounts individual participant accounts Plan Tax Status No evidence IRS tax compliance tests were reviewed No evidence of work performed in support of prior year testing results which resulted in current year return of excess contributions Administrative No work performed Expenses Subsequent Events No documentation of results of inquiries with management No/lack of ASC 820 fair value measurement Compliance with GAAS & GAAP disclosures No subsequent events disclosure Compliance with Incomplete schedule of assets ERISA & DOL Rules Participant loans not disclosed on schedule of assets No 9 Limited DC Planning & No evidence of required 30 Supervision communications(114/115) 401(k) Internal Controls No documentation of SOC1 report controls relied upon No documentation of an assessment of user controls Contributions No test of timely remittance of employee Received & contributions Receivable No recalculation of employee contributions based upon participant election No evidence supporting receipt of contributions & whether receivables should be recognized Benefit Payments Participant confirmations not included in workpapers Participant Data & No/insufficient testing of payroll data Participant Accounts No testing of compliance with compensation provisions Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total plan assets No documentation of parties in Parties in Interest/Prohibited interest/related parties Transactions No documentation of results of inquiries with management 88

91 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type Plan Tax Status No evidence IRS tax compliance tests were reviewed No documentation of results of inquiries with management Commitments & No documentation of results of inquiries Contingencies with management Subsequent Events No documentation of results of inquiries with management 9 Full DC 401(k) Planning & IQPA did not address the $4.7M rollover No 31 Supervision into this new plan in 2011 Lack of documentation of risk Internal Controls assessment procedures Investments & No testing of end of year asset values No testing of investment transactions Investment Transactions No testing of investment income No recalculation of employer and/or Contributions Received & employee contributions No testing of rollover contributions Receivable Benefit Payments No recalculation of benefit payments No/inadequate work regarding eligibility No/inadequate testing of hardship/in- service payments No/insufficient testing of payroll data Participant Data & Participant No testing of compliance with Accounts compensation provisions Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No documentation of parties in Parties in Interest/Prohibited interest/related parties No documentation of results of inquiries Transactions with management Compliance with Inadequate footnote disclosures GAAS & GAAP Opinion does not extend to all Compliance with ERISA & DOL Rules supplemental schedules No/inadequate documentation of internal No 9 Full DC 401(k) Internal Controls 32 control environment No understanding of internal control environment for third party recordkeeper & accounting services 89

92 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Audit Area(s) Detail of Findings Type Scope Findings Member No testing of investment transactions Investments & Investment No testing of investment income No testing of end of year fair values for Transactions investments held in self-directed brokerage accounts No audit program for this area of audit Contributions Received & No agreement of contributions to trust records Receivable No testing/reconciliation of contribution receivable No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of allocations to participant accounts Accounts Inadequate testing of participant investment options Administrative No work performed Expenses Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Inadequate footnote disclosures Compliance with Financial statements did not agree to ERISA & DOL Rules Schedule H Inappropriate items included on the schedule of assets No tax determination letter obtained Minor Item(s): Plan Tax Status Plan Representations not appropriately tailored to plan Representations No 9 Limited DC Planning & No/lack of lack of evidence of audit 33 Supervision planning No/insufficient audit program No/insufficient review of plan documents/operations No work performed Internal Controls No evidence of fraud "brainstorming" Benefit Payments No work performed No work performed Participant Data & Participant Accounts 90

93 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Member Type Parties in No work performed Interest/Prohibited Transactions Plan Tax Status No work performed No work performed Commitments & Contingencies Administrative No work performed Expenses No work performed Subsequent Events Internal Controls No/inadequate documentation of internal No 9 Limited DC 401(k) 34 control environment No/inadequate evidence of fraud "brainstorming" No/inadequate evidence of fraud inquiries Notes Receivable No/inadequate testing of compliance with plan document Contributions No testing of rollover and Roth contributions Received & Receivable Inadequate testing of forfeitures Inappropriate reliance on SOC1 report Participant Data & Participant Inadequate testing of participant investment options Accounts Inadequate testing of allocations to participant accounts No documentation of parties in Parties in Interest/Prohibited interest/related parties Transactions No work performed Administrative Expenses Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Inadequate footnote disclosures Engagement letter language is for a full Minor Item(s): scope audit but a limited scope audit Planning & was performed Supervision Engagement letter is not for the plan No/inadequate work regarding Benefit Payments hardship/in-service payments 91

94 1-2 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Member Scope No 8 Full DC Planning & No/insufficient audit program 35 Supervision Inadequate documentation of plan operations/administration Inadequate preliminary analytic review Inadequate review of workpapers Internal Controls No/inadequate documentation of internal control environment No documentation of evaluation of internal control No review of internal control of service providers Investments & Inappropriate reliance on SOC1 report Investment Inadequate evidence of confirmation of investment ownership and existence with Transactions custodian Contributions No test of timely remittance of employee Received & contributions No testing of compliance with Receivable compensation provisions Inadequate testing of use of forfeitures Participant Data & No/insufficient testing of payroll data Inadequate testing of allocations to Participant Accounts participant accounts Inadequate testing of participant investment options Compliance with Inadequate footnote disclosures GAAS & GAAP No work performed - IQPA indicated "n/a" Minor Item(s): Commitments & Contingencies Inadequate evidence of review of Subsequent Events subsequent financial information Inadequate evidence of specific inquiries Contributions 8 Limited DC 401(k) No No recalculation of employer and/or 36 Received & employee contributions Receivable Inadequate testing of allocations to Participant Data & Participant participant accounts Inadequate testing of participant Accounts investment options Compliance with Inadequate footnote disclosures GAAS & GAAP Compliance with No/inadequate footnote disclosures ERISA & DOL Rules 92

95 1-2 Plan Stratum EBPAQC # of Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type SOC1 reports did not cover entire period Minor Item(s): and no review of controls outside of the Internal Controls SOC1 report period No evidence of review of payroll internal controls or SOC1 report of payroll provider Parties in No documentation of parties in Interest/Prohibited interest/related parties Transactions No evidence IRS tax compliance tests Plan Tax Status were reviewed Subsequent Events No review interim financial data No 7 Limited DC 403b Planning & No/inadequate procedures on 37 initial/beginning balances Supervision Internal Controls No/inadequate evidence of fraud brainstorming" No work performed Benefit Payments Participant Data & Inadequate testing of participant Participant investment options Accounts Parties in No work performed Interest/Prohibited Transactions Commitments & No work performed Contingencies Subsequent Events No work performed Yes 7 Limited DC 403b Investments & Uncertified investments/transactions not 38 Investment audited Transactions No reconciliation of investment income to financial statements No testing of compliance with Contributions compensation provisions Received & Receivable No reconciliation of contributions per sponsor records to custodian records Inadequate testing of Participant Data & Participant eligibility/terminations/forfeitures Accounts Inadequate testing of allocations to participant accounts Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Inadequate footnote disclosures 93

96 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type No/insufficient review of plan Minor Item(s): documents/plan operations Planning & Supervision Notes Receivable Inadequate documentation of testing of participant loans for compliance with plan document Subsequent No documentation of results of inquiries Events with management Planning & No Limited- No/insufficient review of plan DC 401(k) 7 39 Supervision Scope documents/plan operations No assessment/documentation of control Internal Controls risk No evidence of SOC1 report review reliance Audit workpapers did not contain the Investments & Investment certification Transactions No/insufficient testing of payroll data Participant Data & Participant No testing of compliance with compensation provisions Accounts No reconciliation of participant accounts to total assets Commitments & No work performed Contingencies No work performed Administrative Expenses Subsequent No work performed Events No/inadequate procedures on Planning & Yes 7 Limited DC 401(k) 40 Supervision initial/beginning balances No verification of balances transferred from/to new custodian Investments & No/inadequate testing of change in Investment service provider No testing of assets transferred from Transactions plan Notes Receivable No evidence of work performed Contributions No recalculation of employer and/or employee contributions Received & Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions Inadequate testing of use of forfeitures 94

97 1-2 Plan Stratum Review EBPAQC Plan # of Audit Audit Area(s) Detail of Findings Findings Scope Member Type # Participant Data & No/inadequate testing of change in Participant service provider Accounts Inadequate testing of allocations to participant accounts No reconciliation of participant accounts to total assets No documentation of parties in Parties in Interest/Prohibited interest/related parties IQPA did not adequately and accurately Transactions identify accounting and reporting with parties in interest Compliance with Required schedules not ERISA & DOL Rules attached/prepared No evidence of SOC1 report review No 7 Limited DC 401(k) Internal Controls 41 reliance No documentation of an assessment of user controls No/inadequate testing of compliance with Notes Receivable plan document No review of supporting loan documents No listing of outstanding loans No work performed Benefit Payments Total per financial statements was not reconciled to total per the trust report No reconciliation of participant accounts Participant Data & Participant to total assets Accounts No evidence of testing of allocation of investment income to participant accounts No review of interim financial data Subsequent Events No documentation of parties in r Item(s): Mino interest/related parties Parties in No tax determination letter obtained Interest/Prohibited Transactions Plan Tax Status DC No 7 Limited Planning & No/inadequate procedures on 42 Supervision initial/beginning balances No audit work on opening balances of participant accounts No/insufficient review of plan documents/operation 95

98 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Type Scope Findings Member No evidence of SOC1 report review reliance Minor Item(s): No identification of initial audit Internal Controls engagement risks No evidence of review of SOC1 report user controls IQPA did not address internal controls over participant accounts from plan inception thru 12/31/2010 Investments & No documentation of any audit procedures Investment on opening investment balances for initial plan audit Transactions Notes Receivable No/inadequate testing of compliance with plan document No test of timely remittance of employee Contributions Received & contributions Receivable Inadequate testing of use of forfeitures Unclear how employer & employee contributions were tested Unclear how census data was tested for proper inclusion/exclusion Unclear how forfeiture amount and disposition tested Benefit Payments Inadequate evidence regarding amount or propriety of approval for payment Unclear how benefit was recalculated for accuracy, how vesting was tested or how forfeitures were tested Participant Data & No/insufficient testing of payroll data Participant Inappropriate reliance on SOC1 report Inadequate testing of allocations to Accounts participant accounts Inadequate testing of participant investment options No evidence of testing opening participant balances from plan inception to 12/31/2010 No/insufficient review of plan Planning & No 7 Limited DC 401(k) 43 documents/plan operations Supervision Internal Controls No evidence of SOC1 report review reliance No recalculation of employer and/or Contributions Received & employee contributions No test of timely remittance of employee Receivable contributions No recalculation of benefit payments Benefit Payments No/inadequate work regarding eligibility No/inadequate work regarding validity of claims 96

99 1-2 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of Accounts eligibility/terminations/forfeitures Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Compliance with Filing contained Schedules A for welfare ERISA & DOL Rules benefits but there was no evidence of review to determine whether a separate filing should be made for a welfare plan Inadequate work Minor Item(s): Parties in Interest/Prohibited Transactions No/insufficient testing of payroll data No 6 Limited DC 401(k) Participant Data & 44 Participant No testing of compliance with Accounts compensation provisions Inadequate testing of participant investment options Compliance with Delinquent employee contributions were not reported/disclosed ERISA & DOL Rules No review of internal control of service Minor Item(s): providers Internal Controls Control risk assessed at moderate/low with no supporting documentation Contributions Documentation issues make it unclear as Received & to whether proper compensation was Receivable used & whether employee contributions were recalculated IQPA concluded timely remittance when evidence supports they were untimely Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No testing to determine receipt of payment Parties in No disclosure of prohibited transactions Interest/Prohibited in notes to the financial statements Transactions No/inadequate documentation of effect of party in interest/prohibited transactions on financial statements Internal Controls DC Limited No 6 No review of internal control of service 45 providers 97

100 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type No recalculation of employer and/or Contributions Received & employee contributions Receivable Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No recalculation of benefit payments Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of allocations to participant accounts Accounts Inadequate testing of participant investment options Compliance with Inadequate footnote disclosures GAAS & GAAP No review of interim financial data Minor Item(s): Subsequent Events 6 Limited DC 401(k) Internal Controls No/inadequate documentation of internal No 46 control environment No/Inadequate assessment of control risk Lack of documentation of risk assessment procedures No/inadequate evidence of fraud "brainstorming" Notes Receivable No/inadequate testing of compliance with plan document No test of timely remittance of employee Contributions Received & contributions Receivable Participant Data & Inadequate testing of allocations to Participant participant accounts Accounts No work performed Parties in Interest/Prohibited Transactions Plan Tax Status No tax determination letter obtained No/insufficient review of plan Yes 5 Limited DC 401(k) Planning & 47 Supervision documents/plan operations No evidence off required communications (114/115) No evidence of determination of audit materiality No documentation of evaluation of Internal Controls internal control Lack of documentation of risk assessment procedures IQPA did not obtain and review SOC1 report covering 6 months of the plan year 98

101 1-2 Plan Stratum EBPAQC # of Audit Plan Audit Area(s) Detail of Findings Review # Scope Type Findings Member Participant Data & No/insufficient testing of payroll data Participant Accounts Parties in Inadequate work Interest/Prohibited Transactions Subsequent No review of interim financial data Events DC 401(k) No 5 Limited Planning & No/inadequate procedures on 48 Supervision initial/beginning balances Internal Controls No/inadequate documentation of internal control environment Inadequate testing of allocations to Minor Item(s): participant accounts Participant Data & Inadequate testing of participant Participant investment options Accounts Parties in Incomplete list of parties in interest Interest/Prohibited Transactions Compliance with Inadequate footnote disclosures Interest income from participant loans GAAS & GAAP not segregated from investment income 5% investment disclosure incorrectly includes participant loans Notes Receivable No 5 No/inadequate testing of compliance DC 401(k) Limited 49 with plan document Parties in Inadequate work Interest/Prohibited No documentation of parties in interest/related parties Transactions No documentation of results of inquiries with management No work performed Administrative Expenses No/lack of ASC 820 fair value Compliance with measurement disclosures GAAS & GAAP Inadequate footnote disclosures No/inadequate footnote disclosures Compliance with ERISA & DOL Rules IQPA unable to explain $21,530 in deemed distribution loans, principal and interest 99

102 1-2 Plan Stratum EBPAQC # of Audit Plan Review # Audit Area(s) Detail of Findings Type Scope Findings Member Limited 5 DC 401(k) Planning & No No/insufficient review of plan 50 documents/plan operations Supervision Inadequate supervision, governance communications, preliminary analytical review and risk assessments Inadequate testing of participant Contributions Received & deferrals Inadequate documentation related to Receivable late remittances No/inadequate documentation of internal Minor Item(s): control environment Internal Controls Inadequate documentation of sponsor payroll system Inappropriate communication that no significant deficiencies were identified Notes Receivable Inappropriately presented as investments Lack of documentation of census and Participant Data & Participant demographic information Accounts No No tracing of benefit payment to DC 401(k) Benefit Payments 5 Limited 51 participant's account Participant Data & Inadequate testing of allocations to participant accounts Participant Inadequate testing of participant Accounts investment options No evidence IRS tax compliance tests Plan Tax Status were reviewed Commitments & No documentation of results of inquiries Contingencies with management No work performed Administrative Expenses No/inadequate testing of change in 5 Limited DC 401(k) Participant Data & No 52 Participant service provider Inadequate testing of Accounts eligibility/terminations/forfeitures Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Subsequent Events No review of interim financial data No evidence IRS tax compliance tests Minor Item(s): were reviewed Plan Tax Status Compliance with Inadequate footnote disclosures GAAS & GAAP 100

103 1-2 Plan Stratum # of EBPAQC Audit Plan Finding Audit Area(s) Detail of Findings Review # Scope Member Type s Compliance with t attached/prepared Required schedules no ERISA & DOL Rules Missing schedule of reportable transactions Inaccurate footnote wording Schedule of assets does not identify parties in interest Investments & No testing of investment transactions 5 Full DC 401(k) No 53 No testing of investment income Investment Transactions No work performed Parties in Interest/Prohibited Incomplete list of parties in interest Transactions No/inadequate evidence of fraud Minor Item(s): "brainstorming" Internal Controls Participant Data & Inappropriate reliance on SOC1 report Inadequate testing of allocations to Participant Accounts participant accounts Inadequate testing of participant investment options No evidence IRS tax compliance tests were Plan Tax Status reviewed No 4 Limited DC 401(k) Investments & Unsigned certification 54 Investment Transactions Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of allocations to participant accounts Accounts Inadequate testing of participant investment options Compliance with Schedule H, Line 3, audit opinion type not ERISA & DOL Rules properly completed Limited scope audit disclosure incorrectly Minor Item(s): includes contributions and benefit Compliance with payments GAAS & GAAP No 4 DC 401(k) Planning & No/lack of lack of evidence of audit planning Limited 55 Supervision No/inadequate assessment of risk No/inadequate review of plan documents/operations No evidence of required communications (114/115) No evidence of work performed Internal Controls No/inadequate evidence of fraud "brainstorming" No/inadequate documentation of internal control environment No assessment/documentation of control risk 101

104 1-2 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Plan Tax Status No work performed Administrative No work performed Expenses Planning & No DC 401(k) Limited No engagement letter 4 56 Supervision Parties in No work performed Interest/Prohibited Transactions Audit report did not contain the Compliance with "independent" title GAAS & GAAP Compliance with Unsigned IQPA report ERISA & DOL Rules DC No 4 Limited Internal Controls No/inadequate evidence of fraud " 57 brainstorming" Participant Data & Inadequate testing of allocations to Participant participant accounts Accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets Compliance with No/lack of ASC 820 fair value GAAS & GAAP measurement disclosures Inadequate footnote disclosures Unsigned IQPA report Compliance with ERISA & DOL Rules Limited scope audit incorrectly applied Yes 4 Limited DC Benefit Payments No/inadequate work regarding eligibility 58 of individuals receiving benefits No recalculation of benefit payments Inadequate testing of allocations to Participant Data & Participant participant accounts Accounts Parties in Inadequate work Interest/Prohibited Transactions Administrative Inadequate work Expenses 102

105 1-2 Plan Stratum # of EBPAQC Review Plan Audit Finding Audit Area(s) Detail of Findings Scope Type # Member s No 3 Limited DC Contributions No recalculation of employer and/or 59 Received & employee contributions Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions Participant Data & No testing of compliance with Participant compensation provisions Inadequate testing of allocations to Accounts participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets No evidence IRS tax compliance tests Minor Item(s): were reviewed Plan Tax Status Inadequate testing of allocations to Yes 3 Limited DC 401(k) Participant Data & 60 Participant participant accounts Accounts No reconciliation of participant accounts to total assets Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Inadequate footnote disclosures No documentation of parties in Minor Item(s): interest/related parties Parties in Interest/Prohibited Transactions No 3 Limited DC Parties in No work performed 61 Interest/Prohibited Transactions Commitments & No work performed Contingencies No work performed Subsequent Events No 3 Limited DC Investments & Audit workpapers did not contain the 62 certification Investment Transactions Certification obtained was dated 3/21/14, subsequent to audit report date of 10/5/12 No recalculation of employer and/or Minor Item(s): employee contributions Contributions No/insufficient testing of payroll data Received & Inappropriate reliance on SOC1 report Receivable Inadequate testing of allocations to Participant Data & participant accounts Participant Accounts 103

106 1-2 Plan Stratum Audit Plan # of EBPAQC Audit Area(s) Detail of Findings Review # Findings Type Member Scope No 3 Limited DC 401(k) Participant Data & No/insufficient testing of payroll data 63 Inadequate testing of Participant Accounts eligibility/terminations/forfeitures Inadequate testing of allocations to participant accounts No evidence of SOC1 report review Minor Item(s): reliance Internal Controls Plan Tax Status No evidence IRS tax compliance tests were reviewed No test of timely remittance of employee No 3 Full DC Contributions 64 Received & contributions Receivable Participant Data & Inadequate testing of allocations to Participant participant accounts Accounts No work performed Administrative Expenses No 3 Limited DC 401(k) Participant Data & No work performed 65 Participant Accounts Parties in No work performed Interest/Prohibited Transactions Failure to document the reason for no Minor Item(s): contributions being made Contributions Received & Receivable No 3 Limited DC 401(k) Compliance with Unsigned IQPA report 66 ERISA & DOL Rules Inadequate documentation of testing Minor Item(s): individual account income postings Participant Data & Participant Accounts Compliance with Supplemental schedules not referenced in paragraphs 1 and 3 of audit report GAAS & GAAP DC 401(k) No 2 Limited Participant Data & Inadequate testing of allocations to 67 Participant participant accounts Accounts Inadequate footnote disclosures Minor Item(s): Compliance with GAAS & GAAP 104

107 1-2 Plan Stratum # of Audit Plan EBPAQC Detail of Findings Review # Audit Area(s) Scope Member Findings Type Yes IPG contract excluded from plan's Full DB Investments & 2 68 Investment financial statements Transactions No accounting analysis supporting conclusion for excluding IPG contract from financial statement reporting No copy of IPG contract in file Compliance with IPG contract of $4.5M excluded from the financial statements GAAS & GAAP Lack of consideration of report modification for significant uncertainty for rehabilitation plan to avoid insolvency Inadequate footnote disclosures Audit workpapers did not contain the Investments & No 2 Limited DC 69 Investment certification Transactions Participant Data & No/insufficient testing of payroll data Participant Accounts No assessment/documentation of No 2 Limited DC Internal Controls 70 control risk No/inadequate evidence of fraud "brainstorming" No/inadequate documentation of internal control environment Lack of documentation of risk assessment procedures Audit workpapers did not contain the Investments & Investment certification Transactions Investments & DC No Unsigned certification Limited 1 71 401(k) Investment Transactions Inadequate footnote disclosures DC Limited No 1 Compliance with 72 Incomplete schedule of assets GAAS & GAAP 105

108 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Type Scope Findings Member No Planning & Full DC 401(k) 15 No/insufficient review of plan 1 Supervision documents/plan operations No evidence of required communications (114/115) No evidence of preliminary analytics Partner sign-off date was 3 days after audit report date Investments & No work performed Investment Transactions Contributions No test of timely remittance of employee Received & contributions No testing of compliance with Receivable compensation provisions Inadequate testing of use of forfeitures Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No recalculation of benefit payments No/inadequate work regarding forfeitures No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of participant eligibility/terminations/forfeitures Accounts Inadequate testing of allocations to participant accounts No reconciliation of participant accounts to total assets Parties in Inadequate work Interest/Prohibited Transactions Administrative No work performed Expenses Subsequent Events Inadequate documentation - unable to determine accounting records or data reviewed, with whom inquiries were made, and result of such inquiries Compliance with Inadequate footnote disclosures GAAS & GAAP Audit report did not refer to supplemental information Incomplete audit report attached to Form Compliance with ERISA & DOL Rules 5500 Schedule of assets did not indicate parties in interest No/inadequate documentation of internal Minor Item(s): control environment Internal Controls Lack of documentation of risk assessment procedures No/inadequate evidence of fraud "brainstorming" 106

109 3-5 Plan Stratum Plan # of EBPAQC Audit Audit Area(s) Review # Detail of Findings Type Findings Member Scope Notes Receivable Inadequate testing of existence No participant confirmations No evidence of examination of promissory notes No test of interest income Plan Tax Status Tax compliance testing was for 2010, not 2011, and impact was not posted nor accumulated in the summary of uncorrected misstatements Commitments & Inadequate work Contingencies Plan Inappropriate representation letter date Representations Representations not appropriately tailored to plan No/lack of lack of evidence of audit Planning & No 13 Limited DC 401(k) 2 planning Supervision No evidence of required communications (114/115) No assessment/documentation of control Internal Controls risk Lack of documentation of risk assessment procedures Investments & Improper reference to and reliance on certifying entity Investment Transactions No work performed Notes Receivable No/inadequate testing of compliance with plan document Contributions No work performed Received & Receivable Benefit Payments No work performed Participant Data & No work performed Participant Accounts Parties in No work performed Interest/Prohibited Transactions Inadequate work Plan Tax Status No evidence IRS tax compliance tests were reviewed Administrative No work performed Expenses No work performed Subsequent Events 107

110 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Member Type Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inappropriate presentation of participant loans No adjustment from fair value to contract value for fully-benefit responsive contract Inappropriate reference to certifying Compliance with ERISA & DOL Rules entity Incomplete schedule of assets Health No 13 Full Planning & No/insufficient review of plan 3 documents/plan operations Supervision No evidence of required communications (114/115) Insufficient analytical procedures Insufficient work performed Investments & Investment Transactions IQPA did not identify inconsistency in Contributions Received & COBRA contributions Receivable IQPA did not determine if reinsurance receivable was complete Inappropriate reliance on SOC1 report Benefit Payments No/inadequate work regarding validity of claims IQPA did not identify inconsistency in COBRA contributions and the lack of reporting of dental and vision claims Subsequent Events Inadequate work Inappropriate presentation of financial Compliance with information on financial statements GAAS & GAAP Report not modified for lack of ERISA schedules Compliance with Report is not for the plan ERISA & DOL Rules Inadequate testing of participant Minor Item(s): eligibility/terminations/forfeitures Participant Data Inadequate resolution and conclusion on errors noted Plan Obligations No/inadequate testing of IBNR No disclosure of prohibited transactions Parties in Interest/Prohibited in notes to financial statements Inadequate documentation regarding Transactions large claims for a related party to support conclusion Plan Tax Status No evidence IRS tax compliance tests were reviewed Administrative Inadequate work Expenses 108

111 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type Plan Representations not appropriately Representations tailored to plan Planning & No 13 Limited DC 401(k) No/lack of lack of evidence of audit 4 planning Supervision No/insufficient review of plan documents/plan operations No evidence of required communications (114/115) Inadequate supervision/untimely partner review No/inadequate documentation of internal Internal Controls control environment No evidence of SOC1 report review reliance No/inadequate evidence of fraud" brainstorming" Lack of documentation of risk assessment procedures Unexplained variance in certified Investments & Investment participant loan total Transactions Notes Receivable No evidence of work performed No/inadequate testing of compliance with plan document No test of timely remittance of employee Contributions Received & contributions Receivable No testing of compliance with compensation provisions Inadequate reconciliation of contributions received and receivable Inadequate resolution of variance in deferral percentages and participant elections Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No recalculation of benefit payments No/inadequate testing of hardship/in- service payments Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of participant Accounts eligibility/terminations/forfeitures Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets 109

112 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Member Type Parties in Inadequate work Interest/Prohibited No documentation of results of inquiries with management Transactions Plan Tax Status Incorrect tax determination letter Plan document is outdated Footnotes did not match plan document Footnotes did not address tax uncertainties Inadequate work Commitments & Contingencies Subsequent Events Inadequate work No review of interim financial data Compliance with Inadequate footnote disclosures Delinquent employee contributions not GAAS & GAAP reported/disclosed Compliance with No/inadequate footnote disclosures ERISA & DOL Rules Delinquent employee contributions not reported/disclosed No 13 Limited DC 401(k) Internal Controls No documentation of evaluation of 5 internal control No/inadequate evidence of fraud "brainstorming" No review of internal control of service provider(s) Investments & Audit workpapers did not contain the certification Investment Transactions Inadequate testing of change in service provider No comparison/reconciliation of certified income to amount reported on financial statements No testing of compliance with Contributions Received & compensation provisions Inadequate testing of timely remittance Receivable of employee contributions Inadequate testing of employer contributions which appear to have not been made in accordance with the plan document No/inadequate work regarding eligibility Benefit Payments of individuals receiving benefits No recalculation of benefit payments Inadequate work regarding participant receipt No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of participant Accounts eligibility/ terminations/forfeitures Inadequate testing of allocations to participant accounts No reconciliation of participant accounts to total assets 110

113 3-5 Plan Stratum EBPAQC Audit # of Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type Plan Tax Status IRS determination letter was not reviewed or which was for the correct plan Inconsistent documentation regarding compliance tests No documentation of results of inquiries with management Commitments & No documentation of results of inquiries Contingencies with management Subsequent Events Inadequate work Insufficient documentation of inquiries and procedures performed Compliance with Delinquent employee contributions not ERISA & DOL Rules reported/disclosed t attached/prepared Required schedules no Some assets on Schedule of Assets did not indicate parties in interest No/insufficient audit program Minor Item(s): Ineffective analytics did not identify Planning & potential misstatements Supervision Partner signoffs after audit report date Parties in No documentation of results of inquiries Interest/Prohibited with management Transactions Administrative Inadequate work Expenses Compliance with Inadequate footnote disclosures GAAS & GAAP Report not modified for lack of ERISA schedules No/insufficient review of plan Yes 12 Full DB Planning & 6 Supervision documents/operation No evidence of IQPA consideration of plan termination in planning audit procedures for a liquidation basis for investments and accumulated plan benefit obligations IQPA did not identify audit risks related to Internal Controls a liquidation basis for non-marketable investments, accumulated plan benefit obligations, nor benefit payments subsequent to plan termination Investments & No verification of existence of investments, IQPA relied on SOC1 report Investment IQPA did not address liquidation basis for Transactions non-marketable securities and insurance contracts Contributions No evaluation of any required employer contribution receivable that might result Received & Receivable from any unfunded accumulated benefit obligation resulting from plan termination No recalculation of benefit payments Benefit Payments 111

114 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type Participant Data IQPA did not obtain or evaluate any census data based on the premise that an actuarial report did not need to be obtained for a terminated plan Plan Obligations No liquidation basis actuarial report obtained for the terminated plan Parties in No work performed Interest/Prohibited Transactions Plan Mergers & No liquidation basis actuarial report Terminations obtained No evaluation of potential employer contribution on liquidation basis No audit procedures performed on plan liquidation occurring during the subsequent events time period IQPA did not obtain evidence of complete Subsequent Events liquidation of the plan by 7/25/12 Plan No evaluation of numerous Representations representations that were inconsistent with information known by the auditor Audit workpapers did not document Compliance with GAAS & GAAP sufficient appropriate audit evidence to support the unqualified opinion 12 Limited DC Planning & No No/lack of evidence of audit planning 7 No/insufficient audit program Supervision No/inadequate procedures on initial/beginning balances No/inadequate documentation of internal Internal Controls control environment No review of internal control of service provider(s) Audit workpapers did not contain the Investments & Investment certification Transactions Certification was not consistent with the plan reporting period Notes Receivable No work performed Contributions No work performed Received & Receivable No work performed Benefit Payments Participant Data & No testing of compliance with compensation provisions Participant Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets 112

115 3-5 Plan Stratum EBPAQC # of Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Parties in No documentation of parties in interest/related parties Interest/Prohibited Transactions Inadequate work Plan Tax Status No evidence IRS tax compliance tests were reviewed No tax determination letter obtained Commitments & Inadequate work Contingencies Administrative No work performed Expenses Subsequent Events No work performed No 11 Limited DC 403b Internal Controls Lack of documentation of risk 8 assessment procedures No evidence of SOC1 report review reliance Contributions No recalculation of employer and/or Received & employee contributions Receivable No test of rollovers for compliance with plan document Benefit Payments No testing of approvals, proper payee, proper distribution amount, proper payment to proper payee, and rollovers for compliance with plan document No testing of compliance with Participant Data & Participant compensation provisions Inadequate testing of allocations to Accounts participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets No work performed Parties in No documentation of parties in Interest/Prohibited Transactions interest/related parties Plan Tax Status No work performed Commitments & No work performed Contingencies No work performed Subsequent Events Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inadequate footnote disclosure for investments Improper reporting in auditor's report of benefit responsive and non-benefit- responsive contracts 113

116 3-5 Plan Stratum EBPAQC # of Plan Audit Detail of Findings Review # Audit Area(s) Type Findings Member Scope No/lack of evidence of audit planning Minor Item(s): No/insufficient review of plan Planning & documents/operations Supervision No preliminary analytics with expectations documented Compliance with Unsigned IQPA report ERISA & DOL Rules No/insufficient review of plan No 11 Full DC Planning & 9 Supervision documents/operations No evidence of required communications (114/115) No/inadequate documentation of internal Internal Controls control environment No/inadequate evidence of fraud "brainstorming" Investments & Insufficient work performed No testing of investment transactions Investment Transactions No testing of investment income Notes Receivable No/inadequate testing of compliance with plan document No recalculation of employer and/or Contributions Received & employee contributions No test of timely remittance of employee Receivable contributions No testing of compliance with compensation provisions No schedule of contributions received & receivable Participant Data & Inadequate testing of participant eligibility/terminations/forfeitures Participant Accounts No/insufficient testing of payroll data Inadequate testing of allocations to participant accounts No reconciliation of participant accounts to total assets No work performed Parties in Interest/Prohibited Transactions Commitments & No work performed Contingencies No work performed Administrative Expenses Subsequent Events No work performed Plan Representations not appropriately Representations tailored to plan Inadequate representations No/lack of evidence of audit planning Planning & Health No 11 Full 10 Supervision No/insufficient review of plan documents/operations 114

117 3-5 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Member Findings Type No/inadequate assessment of fraud risk No evidence of required communications (114/115) No evidence of review of workpapers Internal Controls No/inadequate documentation of internal control environment No assessment/documentation of control risk Lack of documentation of risk assessment procedures No/inadequate evidence of fraud inquiries No SOC1 report review, reliance, or test of user controls Contributions No recalculation of employer and/or employee contributions Received & No test of timely remittance of employee Receivable contributions No testing of compliance with compensation provisions No consideration of plan funding status No/inadequate work regarding eligibility Benefit Payments of individuals receiving benefits No/inadequate work regarding validity of claims No recalculation of benefit payments No testing for inclusiveness Participant Data No testing of health coverage plan selected for compliance with participant election Plan Obligations No/inadequate testing of IBNR No testing of insurance premiums paid Parties in No work performed Interest/Prohibited No documentation of parties in Transactions interest/related parties Plan Tax Status No evidence IRS tax compliance tests were reviewed No work performed other than obtaining an IRS determination letter No work performed Administrative Expenses No/lack of ASC 820 fair value Compliance with GAAS & GAAP measurement disclosures Inadequate footnote disclosures Required schedules not Compliance with attached/prepared ERISA & DOL Rules 115

118 3-5 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member Yes 11 Limited DC No evidence of required communications Planning & 11 Supervision (114/115) No evidence of planning analytics Internal Controls Lack of documentation of risk assessment procedures No SOC1 report bridge letter Notes Receivable No/inadequate testing of compliance with plan document Contributions No recalculation of employer and/or employee contributions Received & No testing of compliance with Receivable compensation provisions Inadequate testing of use of forfeitures Benefit Payments No evidence of the performance of substantive audit procedures Participant Data & Inadequate work performed, most standard participant data substantive Participant Accounts audit procedures not performed Parties in No documentation of results of inquiries Interest/Prohibited with management Transactions Plan Tax Status No tax determination letter obtained Subsequent Events No documentation of results of inquiries with management No review of interim financial data Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inadequate footnote disclosures Compliance with Limited scope audit incorrectly applied ERISA & DOL Rules Net income per Form 5500 does not agree to financial statements No 11 Limited DC 401(k) Planning & No evidence of required communications 12 Supervision (114/115) Inadequate supervision, partner review completed after report date No/inadequate documentation of internal Internal Controls control environment Inadequate documentation of risk assessment No/inadequate evidence of fraud "brainstorming" No/inadequate evidence of fraud inquiries Fraud brainstorming and inquiries made after audit report date 116

119 3-5 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Contributions Inadequate testing of recalculation of employee deferrals Received & Receivable Inadequate testing of use of forfeitures No testing of compliance with compensation provisions Non-receipt of employer contribution for 1 sample selection Inadequate testing of rollovers Inadequate sample size No/insufficient testing of payroll data Participant Data & Inadequate testing of participant Participant Accounts eligibility/terminations/forfeitures Inadequate testing of participant investment options Parties in No documentation of results of Interest/Prohibited inquiries with management Inadequate work Transactions No work performed Commitments & Contingencies Subsequent Events No work performed Plan Inappropriate representation letter date Representations Representation letter was not on letterhead of the plan or plan sponsor and signer only identified as "office manager" who is also the signer as plan administrator on the Form 5500 Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inappropriate report date Not all investments were presented in the fair value measurement disclosure Investment amount on financial statements not consistent with footnote disclosures No/inadequate work regarding Minor Item(s): eligibility of individuals receiving Benefit Payments benefits No evidence of testing of receipt of payment Compliance with Required schedules not GAAS & GAAP attached/prepared 117

120 3-5 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Member Scope No 11 Limited DC 401(k) Planning & No/insufficient review of plan 13 Supervision documents/operations No evidence of required communications (114/115) No analytics Internal Controls No/inadequate documentation of internal control environment No assessment/documentation of control risk No/inadequate evidence of fraud "brainstorming" No/inadequate evidence of fraud inquiries No test of timely remittance of employee Contributions Received & contributions Inadequate testing of use of forfeitures Receivable No contribution listing No agreement of contributions per plan sponsor to trust statements No work performed Benefit Payments No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of allocations to participant accounts Accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets Parties in No documentation of results of inquiries Interest/Prohibited with management Transactions Plan Tax Status Plan failed ADP & ACP discrimination testing which required $48,257 in corrective distributions - no evidence of work performed Commitments & No documentation of results of inquiries Contingencies with management No work performed Administrative Expenses No documentation of results of inquiries Subsequent Events with management No review of interim financial data Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Inadequate footnote disclosures 118

121 3-5 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Scope Findings Member Type No/insufficient review of plan No 10 Limited DC 403b Planning & 14 Supervision documents/operations No evidence of required communications (114/115) No preliminary analytics No evidence of planning related to testing of mid-year change in trustee/recordkeeper Internal Controls No documentation of evaluation of internal control No assessment/documentation of control risk No/inadequate evidence of fraud inquiries No evidence of SOC1 report review reliance IQPA did not identify and document all significant audit areas No testing of rollover contributions (13% Contributions Received & of total assets) Receivable Benefit Payments No work performed Inappropriate reliance on SOC1 report Participant Data & No/insufficient testing of payroll data No testing of compliance with Participant Accounts compensation provisions Inadequate testing of participant eligibility/terminations/forfeitures Inadequate testing of allocations to participant accounts No testing of participant accounts at time of change in trustee/third party recordkeeper No reconciliation of participant accounts to total assets Parties in Inadequate work Interest/Prohibited No documentation of parties in interest/related parties Transactions Administrative No work performed Expenses Subsequent Events No work performed Inadequate footnote disclosures Compliance with GAAS & GAAP No ASC 820 fair value measurement disclosure Delinquent employee contributions not reported/disclosed Form 5500 financial information did not Compliance with agree with auditor's report ERISA & DOL Rules 119

122 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Member Type No/lack of lack of evidence of audit No 10 Limited DC 403b Planning & 15 Supervision planning No/insufficient review of plan documents/operations No preliminary analytics with developed expectations No assessment/documentation of control Internal Controls risk No identification of significant audit areas Notes Receivable No/inadequate testing of compliance with plan document No recalculation of employer and/or Contributions Received & employee contributions No testing of compliance with Receivable compensation provisions No testing of rollovers for compliance with plan document Benefit Payments No work performed No/insufficient testing of payroll data Participant Data & Participant No testing of compliance with compensation provisions Accounts Inadequate testing of change in service provider Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Parties in No work performed No documentation of parties in Interest/Prohibited Transactions interest/related parties Commitments & No work performed Contingencies Administrative No work performed Expenses Subsequent Events No work performed No/insufficient review of plan No 10 Limited DC 401(k) Planning & 16 Supervision document/plan operations No evidence of required communications (114/115) No preliminary analytical review procedures Partner review over a month after audit report date No test of timely remittance of employee Contributions Received & contributions Receivable IQPA did not identify and conclude on effects of errors in contributions 120

123 3-5 Plan Stratum EBPAQC # of Audit Plan Audit Area(s) Detail of Findings Review # Scope Type Findings Member Participant Data & Inadequate testing of participant eligibility/terminations/forfeitures Participant Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Parties in No/inadequate evidence of consideration Interest/Prohibited of effect of prohibited transactions/party in interest transactions on financial Transactions statements No documentation of results of inquiries with management Commitments & No work performed Contingencies Subsequent Events No work performed Lack of documentation of risk Minor Item(s): assessment procedures Internal Controls Inadequate documentation of SOC1 report Inadequate work Administrative Expenses Delinquent employee contributions not Compliance with GAAS & GAAP reported/disclosed Compliance with Delinquent employee contributions not ERISA & DOL Rules reported/disclosed No/lack of lack of evidence of audit Planning & No 9 Limited DC 401(k) 17 planning Supervision No/insufficient review of plan documents/operations No review of internal control of service Internal Controls providers Certification not consistent with plan Investments & Investment reporting period No/inadequate testing of change in Transactions service provider No/inadequate testing of compliance Notes Receivable with plan document No testing of delinquent loans No testing of transfer to another custodian Contributions Total contributions per custodian not Received & tied to payroll records Receivable Inadequate testing of forfeitures No work performed Benefit Payments 121

124 3-5 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Participant Data & No/inadequate testing of change in service Participant provider Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets Compliance with Inappropriate presentation of financial information on financial statements GAAS & GAAP Report not modified for lack of ERISA schedules Compliance with Required schedules no t attached/prepared ERISA & DOL Rules Yes 9 Limited DC 401(k) No/insufficient review of plan Planning & 18 documents/plan operations Supervision No materiality determination No preliminary analytics No/inadequate documentation of internal Internal Controls control environment No/inadequate evidence of fraud inquiries Contributions No recalculation of employer and/or employee contributions Received & Receivable Participant Data & Inadequate testing of participant Participant investment options Accounts Parties in No work performed Interest/Prohibited Transactions Plan Tax Status No work performed No work performed Commitments & Contingencies No work performed Administrative Expenses Unsigned plan representation letter Plan Representations Inadequate representations, approximately 10 total representations No/lack of evidence of audit planning Planning & Yes 9 Limited DC 401(k) 19 Improper performance of limited scope Supervision audit No documentation of evaluation of Internal Controls internal control No assessment/documentation of control risk No/inadequate evidence of fraud "brainstorming" No evidence of SOC1 report review reliance 122

125 3-5 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member Notes Receivable No work performed Contributions No test of timely remittance of employee contributions Received & Inadequate testing of use of forfeitures Receivable Inappropriate reliance on SOC1 report Benefit Payments No work performed Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of Accounts eligibility/terminations/forfeitures Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Parties in No documentation of parties in Interest/Prohibited interest/related parties Transactions Plan Tax Status Inadequate work No evidence IRS tax compliance tests were reviewed No work performed Subsequent Events No evidence of required communications No 9 Limited DC Planning & 20 401(k) Supervision (114/115) No documentation of determination of materiality levels Contributions No test of timely remittance of employee contributions Received & No verification of subsequent receipt of Receivable contributions receivable No tracing/comparison of benefit Benefit Payments payment with participant's account Participant Data & No testing of whether newly eligible Participant employees were included in the plan Accounts Plan Tax Status No work performed Administrative No work performed Expenses No work performed Commitments & Contingencies Subsequent Events No work performed No/inadequate testing of compliance Mino r Item(s): with plan document Notes Receivable 123

126 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Type Scope Findings Member No No documentation of current Limited DC Planning & 9 21 Supervision developments and analytics Internal Controls No/inadequate documentation of internal control environment No assessment/documentation of control risk No evidence of SOC1 Report review reliance No/lack of documentation of risk assessment procedures Contributions No test of timely remittance of employee Received & contributions No testing of the posting of Receivable contributions per employer records to employee records Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of allocations to participant accounts Accounts Inadequate testing of participant investment options No work performed Parties in Interest/Prohibited Transactions Plan Tax Status No work performed No work performed Commitments & Contingencies Subsequent Events No work performed Inadequate footnote disclosures Compliance with GAAS & GAAP No 9 Full DC 401(k) No/inadequate documentation of internal Internal Controls 22 control environment No assessment/documentation of control risk No documentation of an understanding & operation of the 5 elements of internal control Investments & No testing of investment income Investment Transaction Notes Receivable No/inadequate testing of compliance with plan document No testing of loan documents No testing of loan interest 124

127 3-5 Plan Stratum EBPAQC # of Plan Audit Review # Detail of Findings Audit Area(s) Findings Type Member Scope Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No recalculation of benefit payments No tracing/comparison of benefit payment with participant's account Parties in No work performed Interest/Prohibited Transactions Plan Tax Status No work performed Commitments & No work performed Contingencies Subsequent Events No work performed Although classified as immaterial, no Minor Item(s): other work performed Administrative Expenses No No/inadequate documentation of 9 Full DC Internal Controls 23 internal control environment No assessment/documentation of control risk No testing of end of year asset values Investments & Investment No testing of investment transactions Transactions No testing of investment income No documentation of work performed related to cash accounts Contributions Insufficient work performed of contributing employers (multi-employer Received & Receivable plans) No recalculation of employer and/or employee contributions No test of timely remittance of employee contributions Inadequate testing of use of forfeitures Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No recalculation of benefit payments No/inadequate work regarding forfeitures No tracing of payments to individual participant accounts No evidence of tests of participant receipt No work performed Participant Data & Participant Accounts Parties in No documentation of parties in Interest/Prohibited interest/related parties Transactions No audit program for this area of audit 125

128 3-5 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Plan Tax Status No evidence IRS tax compliance tests were reviewed No audit program for this area of audit Commitments & No documentation of results of Contingencies inquiries with management No audit program for this area of audit Subsequent Events No work performed No audit program for this area of audit No 8 Limited DC 401(k) Planning & No evidence of required 24 communications (114/115) Supervision Incorrect engagement letter Partner did not participate in team "brainstorming" discussion Internal Controls Lack of documentation of risk assessment procedures No evidence of SOC1 report review reliance No/inadequate evidence of fraud "brainstorming" Contributions No recalculation of employer and/or Received & employee contributions Receivable No testing of compliance with compensation provisions Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No/inadequate work regarding validity of claims No/inadequate testing of hardship/in- service payments No/insufficient testing of payroll data Participant Data & Inadequate testing of Participant Accounts eligibility/terminations/forfeitures Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No documentation of parties in Parties in Interest/Prohibited interest/related parties No documentation of results of Transactions inquiries with management Inadequate representations Plan Representations Representations not appropriately tailored to plan Compliance with Inadequate footnote disclosures GAAS & GAAP 126

129 3-5 Plan Stratum Audit Plan # of EBPAQC Audit Area(s) Detail of Findings Review # Scope Findings Type Member 7 DC 401(k) Internal Controls No/inadequate documentation of internal Limited No 25 control environment No/inadequate evidence of fraud inquiries Contributions No testing of compliance with Received & compensation provisions Receivable Inadequate testing of use of forfeitures Inadequate follow up and conclusion on variances IQPA did not recognize untimely contributions No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of allocations to Accounts participant accounts No reconciliation of participant accounts to total assets Parties in No/inadequate evidence of consideration of effect of prohibited Interest/Prohibited transactions/parties in interest on Transactions financial statements Compliance with Delinquent employee contributions not ERISA & DOL Rules reported/disclosed No/inadequate testing of compliance Minor Item(s): with plan document Notes Receivable No evidence of determination of delinquent loans that should be reported as deemed distributions Compliance with Delinquent employee contributions not GAAS & GAAP reported/disclosed Inadequate footnote disclosures No/inadequate documentation of internal Internal Controls No 7 Limited DC 401(k) 26 control environment No/inadequate evidence of fraud inquiries No testing of compliance with Contributions compensation provisions Received & Receivable Inadequate testing of use of forfeitures Inadequate follow up and conclusion on variances IQPA did not recognize untimely contributions No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of allocations to participant accounts Accounts No reconciliation of participant accounts to total assets 127

130 3-5 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member Parties in No/inadequate evidence of consideration Interest/Prohibited of effect of prohibited transactions/parties Transactions in interest on financial statements Compliance with Delinquent employee contributions not ERISA & DOL Rules reported/disclosed No/inadequate testing of compliance with Minor Item(s): plan document Notes Receivable No evidence of determination of delinquent loans that should be reported as deemed distributions Compliance with Delinquent employee contributions not reported/disclosed GAAS & GAAP Inadequate footnote disclosures Internal Controls Yes 6 No review of internal control of service DC 403b Limited 27 providers Unclear documentation of low & moderate inherent control risk was determined based on errors in prior years in contributions No/inadequate testing of compliance with Notes Receivable plan document No testing for determination of delinquent loans that should be reported as deemed distributions No testing of rollover contributions which Contributions Received & were over the materiality threshold Receivable Investments & Certified investment income does not tie to the financial statements and there was Investment no documentation of a reconciliation of Transactions the variance Inadequate testing of allocations to Minor Item(s): participant accounts Participant Data & Inadequate testing of participant Participant investment options Accounts Parties in No documentation of parties in Interest/Prohibited interest/related parties Transactions Audit program steps marked "n/a" with no explanation of why Compliance with No 6 Limited DC 401(k) Reference made to incorrect, non- 28 ERISA & DOL Rules qualifying, certifying entity in audit opinion No audit evidence of testing of rollover Minor Item(s): contributions Contributions Received & Receivable Inappropriate reliance on SOC1 report Participant Data & Participant Inadequate testing of allocations to Accounts participant accounts 128

131 3-5 Plan Stratum EBPAQC # of Audit Plan Detail of Findings Audit Area(s) Review # Type Member Findings Scope Parties in No documentation of results of inquiries with management Interest/Prohibited Transactions No documentation of results of inquiries Commitments & Contingencies with management Subsequent Events No documentation of results of inquiries with management Yes Limited DC 401(k) Internal Controls No evidence of SOC1 report review 6 29 reliance Participant Data & Failure to test compliance with plan Participant compensation provisions Accounts Inappropriate reliance of SOC1 report Inadequate testing of allocations to participant accounts No reconciliation of participant accounts to total assets Inadequate testing of employee authorizations for deferral amounts & investment elections Parties in No work performed Interest/Prohibited No documentation of parties in Transactions interest/related parties Subsequent Events No work performed No testing of rollovers for compliance Minor Item(s): with plan document Contributions Received & Receivable Administrative Inadequate work Expenses No work performed Benefit Payments No 5 Limited DC 401(k) 30 Inadequate testing of Participant Data & Participant eligibility/terminations/forfeitures Inadequate testing of allocations to Accounts participant accounts Inadequate testing of participant investment options Parties in No work performed Interest/Prohibited Transactions Administrative No work performed Expenses No/lack of ASC 820 fair value Compliance with GAAS & GAAP measurement disclosures 129

132 3-5 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Type Member No 5 Limited DC Internal Controls No/inadequate documentation of internal 31 control environment No bridge letter obtained for financial statement period not covered by the SOC1 report Incomplete list of parties in interest em(s): Minor I t Parties in Interest/Prohibited Transactions Plan Tax Status No evidence IRS tax compliance tests were reviewed Commitments & No documentation of results of inquiries with management Contingencies No documentation of results of inquiries Subsequent Events with management Internal Controls No 5 Limited DC 401(k) No/inadequate documentation of internal 32 control environment No/inadequate evidence of fraud "brainstorming" No testing of rollover contributions Contributions Received & which were nearly 4.5 times the materiality threshold Receivable Participant Data & No testing of compliance with Participant compensation provisions Accounts No/insufficient review of plan Minor Item(s): documents/plan operations Planning & Inadequate evidence of timely partner Supervision review of workpapers and audit issues Administrative Inadequate work Expenses No Limited DC Compliance with Total investments per schedule of assets 5 33 did not reconcile to total assets per ERISA & DOL Rules financial statements Audit workpapers did not include a copy Minor Item(s): of the executed plan amendment in Contributions support of the suspension of the Received & employer safe harbor matching Receivable contribution Inadequate testing of allocations to Participant Data & Participant participant accounts Inadequate testing of participant Accounts investment options Inadequate consideration of Parties in Interest/Prohibited prohibited/party in interest transactions Transactions due to suspension of the employer safe harbor match where a copy of executed plan amendment was not obtained 130

133 3-5 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member Plan Tax Status Inadequate consideration of IRC discrimination tests due to suspension of the employer safe harbor match where a copy of the executed plan amendment was not obtained No 5 Full Inadequate testing of Participant Data DB 34 eligibility/terminations/forfeitures No assessment of specialist's Plan Obligations qualifications Administrative No work performed Expenses Subsequent Events Inadequate review through 10/1/12 of final 5500 filing in which benefits paid were materially greater that the accumulated benefit obligation reflected on the 12/31/11 statement of accumulated plan benefits Plan failed to report on the liquidation Compliance with GAAS & GAAP basis of accounting and the IQPA failed to evaluate and/or report on this departure from GAAP No recalculation of employer and/or Contributions No 5 Limited DC 401(k) 35 Received & employee contributions Receivable No test of timely remittance of employee contributions Participant Data & Inadequate testing of allocations to Participant participant accounts Accounts Inadequate testing of participant investment options Parties in No documentation of parties in Interest/Prohibited interest/related parties Transactions Administrative No work performed Expenses No work performed Subsequent Events No 5 Full Health Internal Controls No review of internal control of service 36 providers No recalculation of employer and/or Contributions Received & employee contributions No test of timely remittance of employee Receivable contributions No recalculation of benefit payments Benefit Payments Plan Obligations No test of insurance premiums paid Inadequate work Administrative Expenses 131

134 3-5 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Yes 5 Limited DC 401(k) Investments & No evaluation of insurance contract; 37 Investment contract value to fair value; whether Transactions insurance contract is fully-benefit responsive; and failure to analyze pooled separate account for investments in common collective trust/stable value funds Notes Receivable No/inadequate testing of compliance with plan document No listing of outstanding loans Plan Tax Status No work performed Compliance with No/lack of ASC 820 fair value GAAS & GAAP measurement disclosures Inadequate footnote disclosures No testing of material rollover Minor Item(s): contributions Contributions Received & Receivable 5 Limited DC 401(k) Internal Controls No/inadequate documentation of internal No 38 control environment SOC1 report does not cover last 11 months of the plan year No testing of compliance with Minor Item(s): compensation provisions Contributions Inadequate testing of rollover Received & contributions Receivable Improper presentation of forfeitures on the statement of net assets Unclear how premature distribution was Benefit Payments tested for compliance with ERISA, how vesting of terminated participants was tested, and why an apparent deficient pay-out computation did not result in expansion of audit testing Inadequate consideration/communication of internal control deficiencies Participant Data & Inadequate testing of allocations to Participant participant accounts Accounts Inadequate testing of participant investment options Inadequate documentation of testing of sponsor payroll process Inadequate testing of eligible compensation Plan Tax Status No evidence IRS tax compliance tests were reviewed 132

135 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Type Member No/inadequate documentation of internal Yes 5 Limited DC Internal Controls 39 control environment Participant Data & Inappropriate reliance on SOC1 report Inadequate testing of allocations to Participant Accounts participant accounts Inadequate testing of participant investment options No documentation of parties in Parties in Interest/Prohibited interest/related parties Transactions Administrative No work performed Expenses Area classified as immaterial but no other work or audit program Interest income on notes receivable not Minor Item(s): segregated from investment income Compliance with GAAS & GAAP Certifying entity does not qualify for Investments & No 5 Limited Health 40 Investment limited scope Transactions No work performed Plan Obligations Administrative Inadequate work Expenses Plan No plan representation letter Representations Failure to refer to supplemental info. Compliance with (e.g., ERISA required schedules) GAAS & GAAP Yes Limited DC Internal Controls No evidence of SOC1 report review 4 41 reliance No/insufficient testing of payroll data Participant Data & Participant Accounts Parties in No work performed Interest/Prohibited Transactions Inadequate work Subsequent Events No 4 Limited DC 401(k) Investments & Audit workpapers did not contain the 42 certification Investment Transactions No/inadequate testing of change in service provider Uncertified investments and/or transactions not audited Contributions No testing of contributions receivable Received & Receivable 133

136 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Member Type Participant Data & No/inadequate testing of change in service provider Participant Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets No work performed Parties in Interest/Prohibited Transactions No assessment/documentation of control DC 401(k) 4 Limited Yes Internal Controls 43 risk No documentation of inherent/control risk or combined risk for each significant audit area Inappropriate reliance on SOC1 report Participant Data & Participant Inadequate testing of allocations to participant accounts Accounts Inadequate testing of participant investment options Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Inadequate footnote disclosures Compliance with Incomplete schedule of assets ERISA & DOL Rules No 4 Limited DC 401(k) Internal Controls No/inadequate documentation of internal 44 control environment No documentation of evaluation of internal control No assessment/documentation of control risk Lack of documentation of risk assessment procedures No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of allocations to Accounts participant accounts Parties in No documentation of parties in Interest/Prohibited interest/related parties Transactions No/lack of ASC 820 fair value Compliance with GAAS & GAAP measurement disclosures No/inadequate procedures on Planning & No 4 Limited DC 401(k) 45 Supervision initial/beginning balances No test of timely remittance of employee Contributions contributions Received & Receivable 134

137 3-5 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No/inadequate testing of hardship/in- service payments No/inadequate work regarding validity of claims Compliance with No/lack of ASC 820 fair value GAAS & GAAP measurement disclosures Limited scope audit inappropriately applied Opinion does not contain the appropriate language No 4 Limited DC 403b Investments & Inappropriate treatment of contract to 46 fair value adjustment Investment Transactions Notes Receivable No evidence of work performed Contributions No test of timely remittance of employee contributions Received & Receivable Inadequate or incorrect footnote Compliance with GAAS & GAAP disclosures Yes 4 Limited DC 401(k) Parties in Inadequate work 47 No documentation of results of inquiries Interest/Prohibited Transactions with management Plan Tax Status Inadequate work No documentation of results of inquiries with management No evidence of review of IRS compliance test results Subsequent Events Inadequate work No documentation of results of inquiries with management No evidence of review of interim financial data and plan minutes Inadequate work Minor Item(s): No documentation of results of inquiries Commitments & with management Contingencies No work performed No 4 Limited DC 401(k) Parties in 48 Interest/Prohibited Transactions No work performed Plan Tax Status Commitments & No work performed Contingencies No work performed Subsequent Events 135

138 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Type Member Benefit Payments Yes 3 Limited DC 401(k) No/inadequate work regarding eligibility 49 of individuals receiving benefit No/inadequate work regarding validity of claims No recalculation of benefit payments Unsigned IQPA report Compliance with ERISA & DOL Rules No evidence IRS tax compliance tests Minor Item(s): were reviewed Plan Tax Status 3 Full Health Participant Data No/insufficient testing of payroll data No 50 No work performed Parties in Interest/Prohibited Transactions No/lack of ASC 820 fair value Compliance with GAAS & GAAP measurement disclosures No FAS 165 subsequent events disclosure Inadequate footnote disclosures Limited No/inadequate testing of compliance Notes Receivable No 3 DC 403b 51 with plan document No review of loan documentation No review of deemed distributions Contributions No recalculation of employer and/or employee contributions Received & Inadequate work on receivables Receivable Participant Data & No/insufficient testing of payroll data No testing of compliance with Participant Accounts compensation provisions Contributions No No test of timely remittance of employee Limited DC 401(k) 3 52 contributions Received & Receivable Benefit Payments No recalculation of benefit payments Inadequate testing of allocations to Participant Data & Participant participant accounts Inadequate testing of participant Accounts investment options No reconciliation of participant accounts to total assets Certifying entity does not qualify for No 3 Limited DC 401(k) Investments & 53 Investment limited scope Transactions No/insufficient testing of payroll data Minor Item(s): Participant Data & Participant Accounts 136

139 3-5 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type Compliance with Inadequate footnote disclosures GAAS & GAAP Incomplete fair value measurement footnote disclosure No plan amendment disclosure Who pays administrative expenses not disclosed No/Inadequate assessment of control risk No 3 Limited DC 401(k) Internal Controls 54 Lack of documentation of risk assessment procedures Contributions No test of timely remittance of employee contributions Received & Receivable Administrative No work performed Expenses No test of timely remittance of employee No 3 Limited DC 403b Contributions 55 Received & contributions Receivable No evidence IRS tax compliance tests Plan Tax Status were reviewed Compliance with Inappropriate presentation of financial information on financial statements GAAS & GAAP No adjustment on financial statements for fully-benefit responsive investment contract fair value to contract value No review of internal control of service No 2 Limited DC 401(k) Internal Controls 56 provider(s) No/insufficient testing of payroll data Minor Items(s): Participant Data & Participant Accounts No 2 Full Health Benefit Payments No work performed 57 Inappropriate reliance on SOC1 report Unclear documentation regarding review Minor Item(s): of timely remittance of employee Contributions contributions Received & Receivable No testing of compliance with 2 Full DC 401(k) Participant Data No 58 compensation provisions Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets No alternative procedures performed on non-reply participant confirmations 137

140 3-5 Plan Stratum Audit Plan EBPAQC # of Audit Area(s) Detail of Findings Review # Scope Findings Type Member No assessment/documentation of control Minor Item(s): risk Internal Controls Lack of documentation of risk assessment procedures No 2 Limited DC Compliance with Failure to present benefit responsive 59 GAAS & GAAP insurance contract at contract value and make necessary footnote disclosures Inappropriate reliance on SOC1 report Minor Item(s): Participant Data & Participant Accounts No 2 Limited No tax determination letter obtained Plan Tax Status DC 401(k) 60 Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Inadequate footnote disclosures Yes 2 Full Health Administrative No work performed 61 Expenses Incomplete list of parties in interest Minor Item(s): Parties in Interest/Prohibited Transactions No test of timely remittance of employee Yes 2 Limited DC 401(k) Contributions 62 Received & contributions Receivable No evidence IRS tax compliance tests Plan Tax Status were reviewed Yes 1 Full DB Compliance with Opinion does not extend to all financial 63 GAAS & GAAP statements Auditor did not report on prior year financial statements presented No 1 Limited DC 401(k) Benefit Payments No work performed 64 No 1 Full DB Investments & No testing of end of year asset values 65 Investment No testing of investment transactions Transactions No testing of investment income 138

141 6-24 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Member Type No/lack of lack of evidence of audit Yes 13 Full DC 401(k) Planning & 1 Supervision planning No/insufficient review of plan documents/operations No evidence of required communications (114/115) No/inadequate documentation of internal Internal Controls control environment No assessment/documentation of control risk No documentation of evaluation of internal control No evidence of SOC1 report review reliance Investments & No testing of end of year asset values No testing of investment transactions Investment Transactions No testing of investment income No/inadequate testing of compliance Notes Receivable with plan document Contributions No recalculation of employer and/or Received & employee contributions Receivable No testing of compliance with compensation provisions Inappropriate reliance on SOC1 report Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No/inadequate testing of hardship/in- service payments No/inadequate work regarding validity of claims No/insufficient testing of payroll data Participant Data & Participant Inappropriate reliance on SOC1 report Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Plan Tax Status No evidence IRS tax compliance tests were reviewed Inadequate work performed Commitments & Contingencies No documentation of results of inquiries with management Administrative No work performed Expenses Subsequent Events No work performed Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Participant loan interest and administrative fees not separately disclosed on financial statements 139

142 6-24 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Compliance with Administrative fees not separately presented from benefit payments ERISA & DOL Rules No 13 Limited DC 403b Planning & No/insufficient review of plan 2 Supervision documents/plan operations No evidence of required communications (114/115) Internal Controls No/inadequate documentation of internal control environment No assessment/documentation of control risk No evidence of SOC1 report review reliance Notes Receivable No work performed No/inadequate testing of compliance with plan document Contributions No recalculation of employer and/or Received & employee contributions Receivable No test of timely remittance of employee contributions Inadequate testing of use of forfeitures Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No testing for compliance with plan document No testing of posting of disbursement at individual account level Participant Data & No/insufficient testing of payroll data No testing of compliance with Participant Accounts compensation provisions Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Parties in No work performed No documentation of parties in Interest/Prohibited Transactions interest/related parties Inadequate work Commitments & Contingencies No documentation of results of inquiries with management Administrative No work performed Expenses No work performed Subsequent Events Compliance with No/lack of ASC 820 fair value GAAS & GAAP measurement disclosures 5% investment disclosure note is for the incorrect plan years Compliance with Incomplete schedule of assets ERISA & DOL Rules 140

143 6-24 Plan Stratum # of EBPAQC Audit Plan Review # Audit Area(s) Detail of Findings Type Scope Findings Member Representations not appropriately Minor Item(s): tailored to plan Plan Representations No assessment/documentation of Internal Controls Yes 11 Limited DC 401(k) 3 control risk Lack of documentation of risk assessment procedures No evidence of SOC1 report review reliance No work performed Notes Receivable No audit program for this area of audit Contributions No testing of compliance with Received & compensation provisions Receivable Inadequate testing of use of forfeitures No verification of employer discretionary contribution percentage Participant Data & No/insufficient testing of payroll data Participant Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets Parties in No documentation of results of Interest/Prohibited inquiries with management Transactions Plan Tax Status No work performed Inadequate work Commitments & Contingencies No documentation of results of inquiries with management Subsequent Events No documentation of results of inquiries with management Inadequate work Incorrect ASC 820 fair value Compliance with GAAS & GAAP measurement disclosure Inadequate footnote disclosures No/inadequate work regarding Minor Item(s): forfeitures Benefit Payments Inappropriate representation letter date Plan Representations 141

144 6-24 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Member Findings Type No 11 Limited DC Planning & No/insufficient review of plan 4 Supervision documents/operations No evidence of required communications (114/115) Internal Controls No/inadequate documentation of internal control environment No assessment/documentation of control risk No evidence of SOC1 report review reliance Benefit Payments Inappropriate application of limited scope audit No testing of rollovers out of plan for compliance with plan document Participant Data & No testing of employee withholdings Participant for authorization Inappropriate reliance on SOC1 report Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets Parties in No work performed No documentation of parties in Interest/Prohibited Transactions interest/related parties Administrative No work performed Expenses Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inadequate footnote disclosures Compliance with Auditor's report not included with Form ERISA & DOL Rules 5500 filing No/inadequate testing of compliance Minor Item(s): with plan document Notes Receivable No recalculation of employer and/or Contributions Received & employee contributions Receivable No testing of rollovers into plan for compliance with plan document Subsequent Events No review interim financial data 142

145 6-24 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type No Investments & Limited DC 401(k) 11 Dividend income and net appreciation 5 Investment Income did not tie to financial statements No documentation supporting fair value reported on 5500 - amount marked up to fair value without corresponding adjustment to contract value Notes Receivable No/inadequate testing of compliance with plan document Certification did not cover loans - no testing done on ending values or payments made during the year Contributions No recalculation of employer and/or employee contributions Received & No testing of compliance with Receivable compensation provisions No/inadequate work regarding eligibility Benefit Payments of individuals receiving benefits No recalculation of benefit payments No/inadequate work regarding forfeitures No/insufficient testing of payroll data Participant Data & Participant No testing of compliance with compensation provisions Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Parties in No documentation of parties in Interest/Prohibited interest/related parties No documentation of results of inquiries Transactions with management Subsequent Events No review of interim financial data No inquiries of plan administrator and/or trustee - inquiries were only made of the controller who was not a plan official Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inadequate footnote disclosures No evidence of required communications Minor Item(s): (114/115) Planning & Inadequate documentation showing Supervision proper supervision and timely partner review Plan Tax Status No evidence IRS tax compliance tests were reviewed No tax uncertainty footnote disclosure 143

146 6-24 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Type Member Compliance with Notes receivable from participants were not reflected as parties in interest on ERISA & DOL Rules schedule of assets 10 Limited DB Planning & No/insufficient review of plan Yes 6 documents/operations Supervision No/inadequate assessment of fraud risk No evidence of required communications (114/115) No/inadequate documentation of Internal Controls internal control environment Lack of documentation of risk assessment procedures No/inadequate evidence of fraud inquiries No/inadequate work regarding eligibility Benefit Payments of individuals receiving benefits No recalculation of benefit payments No testing of receipt by participants No work performed Participant Data No/insufficient testing of census data Plan Obligations No assessment of specialist's qualifications No review/assessment of specialist's assumptions No disclosure of prohibited transactions Parties in in notes to financial statements Interest/Prohibited Transactions No documentation of results of inquiries with management Commitments & No work performed Contingencies Administrative No work performed Expenses No work performed Subsequent Events Financial statements were Compliance with GAAS & GAAP inappropriately presented on the liquidation basis - liquidation basis does not apply to frozen plans No reference to the "other comprehensive basis of accounting" used in the report Inappropriately indicated the limited scope covered benefit payments Inadequate footnote disclosures No related party note No assessment/documentation of control Internal Controls Yes 10 Limited DC 401(k) 7 risk No/inadequate evidence of fraud inquiries No evidence of SOC1 report review reliance 144

147 6-24 Plan Stratum # of EBPAQC Audit Plan Review # Audit Area(s) Detail of Findings Type Scope Findings Member No/insufficient testing of payroll data Participant Data & Inadequate testing of allocations to Participant Accounts participant accounts No work performed Parties in Interest/Prohibited No documentation of parties in interest/related parties Transactions Administrative Inadequate work Expenses No work performed Subsequent Events No evidence of review of workpapers Minor Item(s): Planning & Supervision Contributions No testing of rollover contributions for Received & compliance with plan document Receivable Benefit Payments No/inadequate work regarding forfeitures Plan Tax Status No tax determination letter obtained Inadequate work Commitments & Contingencies No/inadequate procedures on Planning & No 10 Limited DC 401(k) 8 Supervision initial/beginning balances No/inadequate work related to predecessor auditors No evidence of required communications (114/115) Inadequate evidence of partner involvement/review No evidence that $1M insurance contract documentation was obtained and reviewed for disclosure and accounting treatment Investments & Certification is not for the plan Investment Inadequate evidence of evaluation of Transactions insurance contract (GIC) for accounting treatment and presentation Inadequate documentation of audit work Plan Mergers & Terminations on subsequent events/pending dissolution of the plan Audit documentation did not indicate Subsequent Events subsequent event of plan asset transfer to a successor plan in 2012 145

148 6-24 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Member Type Compliance with Inadequate footnote disclosures Disclosure omissions: dissolution of plan, GAAS & GAAP subsequent probable distributions/transfers; incomplete tax compliance testing; party in interest transactions, insurance (GIC) contract terms, and improper presentation/disclosure of notes receivable Presented as investments on the plan's Mino Item(s): r financial statements and in the ASC 820 Notes Receivable fair value measurement disclosures Participant Data & No/insufficient testing of payroll data Inadequate testing of allocations to Participant Accounts participant accounts No documentation of parties in Parties in Interest/Prohibited interest/related parties Transactions No evaluation of omission of party in interest disclosure in the financial statements Commitments & Pending dissolution of plan in 2012 and Contingencies transfer to another plan not identified in commitment & contingencies audit workpapers Plan Inconsistent representations regarding Representations tax compliance testing and intention to dissolve plan in 2012 Planning & Yes 10 No/lack of lack of evidence of audit DC 401(k) Limited 9 Supervision planning No/insufficient review of plan documents/operations No/inadequate assessment of fraud risk No assessment/documentation of control Internal Controls risk No/inadequate evidence of fraud "brainstorming" No review of internal control of service providers No evidence of SOC1 report review reliance No/inadequate testing of compliance Notes Receivable with plan Failure to test rollovers to the plan Contributions Received & Receivable 146

149 6-24 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of allocations to Accounts participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets No documentation of results of inquiries Parties in Interest/Prohibited with man agement Transactions Plan Tax Status Inadequate work performed No evidence IRS tax compliance tests were reviewed Commitments & No work performed Contingencies Administrative Inadequate work Expenses Subsequent Events No work performed Limited No 9 DC 401(k) Planning & Inadequate gaining of an understanding 10 Supervision of the plan No/inadequate assessment of fraud risk No planning analytics No/inadequate documentation of Internal Controls internal control environment Lack of documentation of risk assessment procedures No/inadequate evidence of fraud "brainstorming" No/inadequate evidence of fraud inquiries Notes Receivable No work performed No recalculation of employer and/or Contributions employee contributions Received & Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions Benefit Payments No work performed No work performed Participant Data & Participant Accounts No work performed Administrative Expenses Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inadequate footnote disclosures 147

150 6-24 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Compliance with Incomplete schedule of assets ERISA & DOL Rules Yes 9 DC 401(k) Planning & No/insufficient review of plan Full 11 Supervision documents/plan operations No/inadequate assessment of fraud risk Internal Controls No work performed Investments & No testing of assets transferred from the Investment plan No/inadequate testing of change in Transactions service provider No testing of investment transactions Notes Receivable No schedule of participant loans No evidence of review of loan documents No evidence of testing of loan interest No recalculation of employer and/or Contributions Received & employee contributions Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions No/inadequate work regarding eligibility Benefit Payments of individuals receiving benefits No/inadequate work regarding validity of claims No recalculation of benefit payments No/inadequate work regarding use of forfeitures Parties in No documentation of parties in interest/related parties Interest/Prohibited Transactions No documentation of results of inquiries with management Inadequate footnote disclosures Compliance with GAAS & GAAP Compliance with No/inadequate footnote disclosures ERISA & DOL Rules No evidence of required Yes 9 Limited DC 401(k) Planning & 12 Supervision communications(114/115) Internal Controls No/inadequate documentation of internal control environment No documentation of evaluation of internal control No assessment/documentation of control risk No/inadequate evidence of fraud "brainstorming" 148

151 6-24 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Benefit Payments Inappropriate reliance on SOC1 report No/inadequate work regarding forfeitures No testing of rollovers out of plan for compliance with plan document Inadequate testing of propriety of payee Inadequate testing of allocations to Participant Data & Participant participant accounts Accounts No reconciliation of participant accounts to total assets No work performed Parties in Interest/Prohibited No documentation of parties in interest/related parties Transactions Plan Tax Status No evidence IRS tax compliance tests were reviewed Compliance with Incomplete IQPA report attached to ERISA & DOL Rules Form 5500 No/inadequate testing of compliance Minor Item(s): with plan document Notes Receivable First year audit, no testing of detail at individual participant level Inadequate work Administrative Expenses Planning & No 9 Limited DC 401(k) No/lack of lack of evidence of audit 13 Supervision planning No/inadequate assessment of fraud risk No work performed Internal Controls No work performed Notes Receivable Contributions No recalculation of employer and/or Received & employee contributions Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions No disclosure of corrective distributions in the financial statements & footnotes No recalculation of benefit payments Benefit Payments No/inadequate work regarding eligibility No/inadequate work regarding forfeitures No/insufficient testing of payroll data Participant Data & No testing of compliance with Participant Accounts compensation provisions Inadequate testing of allocations to participant accounts No reconciliation of participant accounts to total assets 149

152 6-24 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Type Member Parties in No documentation of parties in interest/related parties Interest/Prohibited No documentation of results of inquiries Transactions with management No procedures performed to verify major areas with parties in interest No work performed Administrative Expenses Inadequate work Subsequent Events Yes 8 Limited DC 401(k) Planning & No/inadequate procedures on 14 initial/beginning balances Supervision No/insufficient review of plan documents/operation Receivables inappropriately accrued Contributions Received & Delinquent contributions on schedule differed to that reported on Schedule H Receivable and in the related workpapers Parties in Inadequate work Interest/Prohibited Transactions No/inadequate work regarding Minor Item(s): forfeitures Benefit Payments Participant Data & No/insufficient testing of payroll data Inadequate testing of Participant Accounts eligibility/terminations/forfeitures No testing of compliance with compensation provisions Inadequate testing of allocations to participant accounts Subsequent Events Inadequate work Plan Representations not appropriately Representations tailored to plan Inadequate footnote disclosures Compliance with GAAS & GAAP Minor presentation items on financial statements Planning & Yes 8 Full DC ESOP No/lack of evidence of audit planning 15 Supervision No/insufficient review of plan documents/plan operations No/inadequate assessment of fraud risk No evidence of required communications (114/115) No/inadequate documentation of internal Internal Controls control environment No assessment/documentation of control risk No/inadequate evidence of fraud inquiries No evidence of SOC1 report review reliance 150

153 6-24 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Investments & No review of investment valuation assumptions Investment Transactions Insufficient work performed Participant Data & No/insufficient testing of payroll data Participant No testing of compliance with compensation provisions Accounts Inadequate testing of allocations to participant accounts No reconciliation of participant accounts to total assets Administrative No work performed Expenses No work performed Subsequent Events Compliance with Inadequate footnote disclosures GAAS & GAAP Inadequate work Minor Item(s): Parties in Interest/Prohibited Transactions Yes 8 Limited DC 403b Notes Receivable No/inadequate testing of compliance 16 with plan document No recalculation of employer and/or Contributions Received & employee contributions No testing of compliance with Receivable compensation provisions No comparison of amount of employer contributions to that approved by the Board of Directors No review of criteria for contribution receivables and proper recording in accordance with GAAP Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No recalculation of benefit payments No/inadequate work regarding validity of claims No testing of compliance with Participant Data & Participant compensation provisions Accounts Inadequate testing of eligibility/terminations/forfeitures Inadequate testing of allocations to participant accounts Compliance with Inadequate footnote disclosures GAAS & GAAP No/inadequate footnote disclosures Compliance with ERISA & DOL Rules 151

154 6-24 Plan Stratum EBPAQC Audit # of Plan Review # Detail of Findings Audit Area(s) Findings Member Type Scope No evidence IRS tax compliance tests Minor Item(s): were reviewed Plan Tax Status Subsequent Events No review of interim financial data Yes 8 Limited DC 401(k) Planning & No/insufficient audit program 17 Supervision Contributions No testing of rollover contributions Received & Receivable Benefit Payments No work performed Participant Data & Inadequate testing of allocations to participant accounts Participant Accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets Parties in No work performed Interest/Prohibited Transactions Plan Tax Status No work performed Commitments & No work performed Contingencies Subsequent Events No work performed No documentation of evaluation of Yes 8 Limited DC 403b Internal Controls 18 internal control No review of internal control of service providers Inconsistent documentation of risk assessment Lack of documentation supporting lowering control risk Contributions No recalculation of employer and/or employee contributions Received & Receivable No testing of compliance with compensation provisions Inadequate testing of rollover contributions IQPA did not address testing errors and the impact on the financial statements Benefit Payments No recalculation of benefit payments No/inadequate work regarding validity of claims No/inadequate testing of compliance Minor Item(s): with plan document Notes Receivable Participant Data & Inadequate testing of Participant eligibility/terminations/forfeitures Accounts Inadequate testing of participant investment options 152

155 6-24 Plan Stratum EBPAQC # of Audit Plan Audit Area(s) Detail of Findings Review # Type Findings Member Scope Plan Tax Status No evidence IRS tax compliance tests were reviewed Compliance with Inadequate footnote disclosures GAAS & GAAP Compliance with Inappropriate financial statement presentations ERISA & DOL Rules 8 Limited DC 401(k) Planning & No No/insufficient audit program 19 Inadequate planning analytical review Supervision Internal Controls Inadequate assessment of control risk Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No/inadequate work regarding validity of claims No/inadequate work regarding forfeitures Inadequate review to ensure compliance with plan document Participant Data & Inadequate testing of allocations to participant accounts Participant Accounts Inadequate testing of participant investment options No work performed Administrative Expenses Compliance with Inappropriate presentation of financial information on financial statements GAAS & GAAP Inadequate footnote disclosures No/inadequate testing of compliance Minor Item(s): with plan document Notes Receivable No evidence of testing rollovers Contributions Received & Inadequate testing of forfeitures Receivable 8 Limited DC 401(k) Contributions Yes No recalculation of employer and/or 20 employee contributions Received & Receivable No test of timely remittance of employee contributions No recalculation of benefit payments Benefit Payments No testing of long outstanding benefit checks No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of allocations to Accounts participant accounts Inadequate testing of participant investment options No reconciliation of participant accounts to total assets 153

156 6-24 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Plan Tax Status No evidence IRS tax compliance tests were reviewed No tax determination letter obtained Administrative No work performed Expenses IQPA did not note fully benefit Minor Item(s): responsive contract and adjustment to Investments & contract value Investment Transactions No documentation of results of inquiries Commitments & Contingencies with management No documentation of results of inquiries Subsequent Events with management No/insufficient review of plan Planning & No 8 Limited DC 403b 21 documents/plan operations Supervision Missing permanent file with vital plan documents No/inadequate testing of compliance Notes Receivable with plan document Inadequate review of loans issued to participants No recalculation of employer and/or Contributions employee contributions Received & Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions Inadequate testing of use of forfeitures No recalculation of benefit payments Benefit Payments No/inadequate work regarding validity of claims No/inadequate work regarding eligibility No schedule of benefits paid to participants provided No/insufficient testing of payroll data Participant Data & Participant No testing of compliance with compensation provisions Accounts Inadequate testing of eligibility/terminations/forfeitures Inadequate testing of participant investment options No documentation of parties in Parties in Interest/Prohibited interest/related parties No documentation of results of inquiries Transactions with management No work performed Plan Tax Status No work performed Administrative Expenses 154

157 6-24 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Type Member Planning & No 8 Limited DC No/lack of lack of evidence of audit 22 planning Supervision No evidence of required communications (114/115) No evidence of supervisory review Internal Controls No work performed No work performed Notes Receivable Benefit Payments No work performed No work performed Participant Data & Participant Accounts Unsigned IQPA report Compliance with ERISA & DOL Rules No documentation of parties in Minor Item(s): interest/related parties Parties in Interest/Prohibited Transactions Compliance with No/lack of ASC 820 fair value GAAS & GAAP measurement disclosures No documentation of significant Planning & No 7 Limited DC 401(k) 23 Supervision conditions and effects on operations No analytics No/inadequate testing of compliance Notes Receivable with plan document No review of loan documents No review of deemed distributions No testing of receivables Contributions Received & Receivable Benefit Payments Inappropriate reliance on SOC1 report No/inadequate work regarding eligibility No/inadequate work regarding validity of claims No recalculation of benefit payments Participant Data & Inadequate testing of allocations to Participant participant accounts Inadequate testing of participant Accounts investment options Parties in Inadequate work Interest/Prohibited Transactions Inadequate work Subsequent Events 155

158 6-24 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type Yes Limited DC 401(k) Planning & No/lack of lack of evidence of audit 7 24 planning Supervision No/insufficient audit program No/insufficient review of plan documents/operations No assessment of fraud risk Internal Controls No evidence of work performed Notes Receivable No/inadequate testing of compliance with plan document Contributions No recalculation of employer and/or Received & employee contributions Receivable Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of participant Accounts investment options Plan Tax Status No evidence IRS tax compliance tests were reviewed No tax determination letter obtained Inadequate work Minor Item(s): Parties in Interest/Prohibited Transactions Yes Internal Controls Limited DB 6 No/Inadequate assessment of control risk 25 No/inadequate evidence of fraud "brainstorming" No/inadequate documentation of internal control environment No documentation of risk of material misstatement Participant Data No testing of the basic data used by the actuary Plan Obligations No/insufficient testing of census data Inadequate work Parties in Interest/Prohibited Transactions Plan Tax Status No work performed Commitments & No work performed Contingencies Yes 6 Limited DC Internal Controls No/inadequate documentation of internal 26 control environment No review of internal control of service providers Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No recalculation of benefit payments 156

159 6-24 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Participant Data & No/inadequate testing of change in service provider Participant Accounts No/insufficient testing of payroll data No reconciliation of participant accounts to total assets Plan Tax Status Compliance tests indicate data integrity issues that could affect the results of the testing, but no indication this was considered No tax determination letter obtained No/inadequate testing of compliance Minor Item(s): with plan document Notes Receivable Compliance with Inappropriate presentation of financial information on financial statements GAAS & GAAP Inadequate footnote disclosures Yes 6 Full DC Internal Controls No review of internal control of service 27 providers Partner not involved in fraud "brainstorming" Sole trustee and person responsible for governance not interviewed for fraud No testing of investment transactions Investments & Investment Insufficient testing of investment income No evidence of testing for existence Transactions Subsequent Events No documentation of results of inquiries with management No review of interim financial data mentation of tests Insufficient 103 docu Minor Item(s): of vesting, eligibility, taxes, rollover Benefit Payments distribution No/insufficient testing of payroll data Participant Data & Participant Accounts Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inadequate footnote disclosures No/insufficient review of plan Planning & DC 401(k) No 6 Limited 28 Supervision documents/plan operations Contributions No recalculation of employer and/or Received & employee contributions Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions Inadequate testing of use of forfeitures 157

160 6-24 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits No recalculation of benefit payments No/inadequate work regarding validity of claims Inadequate testing of Participant Data & eligibility/terminations/forfeitures Participant No/insufficient testing of payroll data Accounts No testing of compliance with compensation provisions Inadequate testing of allocations to participant accounts Parties in No documentation of parties in interest/related parties Interest/Prohibited Transactions No documentation of results of inquiries with management Administrative No work performed Expenses No 6 Limited DC 401(k) Internal Controls No/inadequate documentation of internal 29 control environment Notes Receivable No evidence of work performed No test of timely remittance of employee Contributions Received & contributions Receivable Inadequate testing of allocations to Participant Data & Participant participant accounts Accounts Inadequate testing of participant investment options Incomplete IQPA report attached to Compliance with Form 5500 ERISA & DOL Rules No/inadequate footnote disclosures No work performed Minor Item(s): Administrative Expenses Audit workpapers did not contain the Investments & Yes 6 Limited Health 30 Investment certification Transactions Benefit Payments Inappropriate reliance on SOC1 report Complete reliance placed on SOC1 report to the exclusion of audit work No certification to support the limited Compliance with ERISA & DOL Rules scope audit disclaimer opinion in the audit report Engagement letter was for full scope but Mino r Item(s): limited scope was issued Planning & Workpapers indicated confusion Supervision regarding scope of audit work 158

161 6-24 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member Internal Controls No evidence of SOC1 report review reliance Plan Obligations No/inadequate testing of IBNR Inadequate testing of claims payable Internal Controls Yes 6 Limited No/Inadequate assessment of control DC 403b 31 risk No evidence of SOC1 report review reliance Inappropriate application of limited Benefit Payments scope audit Inappropriate reliance on SOC1 report No/inadequate work regarding eligibility No/insufficient testing of payroll data Participant Data & No testing of compliance with Participant compensation provisions Accounts No testing for compliance with IRS deferral limits No reconciliation of participant accounts to total assets Inadequate testing of participant investment options No work performed Plan Tax Status Administrative No work performed Expenses Inadequate work Minor Item(s): Parties in Interest/Prohibited Transactions Yes 6 Limited DC 401(k) Planning & No/insufficient review of plan 32 Supervision documents/plan operations No/inadequate assessment of fraud risk No evidence of required communications (114/115) Internal Controls No evidence of SOC1 report review reliance No/inadequate evidence of fraud "brainstorming" Contributions No recalculation of employer and/or Received & employee contributions Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions No documentation of parties in Parties in Interest/Prohibited interest/related parties No documentation of results of Transactions inquiries with management 159

162 6-24 Plan Stratum Audit Plan EBPAQC # of Review # Audit Area(s) Detail of Findings Scope Findings Type Member Plan Tax Status No work performed Administrative No work performed Expenses No 5 Limited DC 401(k) Internal Controls No evidence of SOC1 report review 33 reliance Notes Receivable No evidence of work performed No/inadequate testing of compliance with plan document Contributions No test of timely remittance of employee contributions Received & Receivable Participant Data & No/insufficient testing of payroll data Inadequate testing of allocations to Participant participant accounts Accounts Administrative No work performed Expenses Yes 5 Limited DC 401(k) Planning & No/lack of lack of evidence of audit 34 Supervision planning No audit program or insufficient audit program No evidence of review of service provider agreements Inadequate identification of parties in interest for planning No assessment/documentation of control Internal Controls risk Lack of documentation of risk assessment procedures No evidence of SOC1 report review reliance No review of internal control of service providers No testing of compliance with Participant Data & Participant compensation provisions No/insufficient testing of payroll data Accounts No reconciliation of total participant accounts to total assets No documentation of parties in Parties in interest/related parties Interest/Prohibited Transactions Inadequate work Administrative Expenses No 5 Limited DC 403b Benefit Payments Inappropriate reliance on SOC1 report 35 Inadequate testing of allocations to Minor Item(s): participant accounts Participant Data & Participant Accounts 160

163 6-24 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Type Member Parties in No documentation of parties in interest/related parties Interest/Prohibited Transactions Subsequent Events No review of interim financial data Compliance with Inappropriate presentation of financial information on financial statements GAAS & GAAP 5 Limited DC 401(k) Planning & Yes No/insufficient review of plan 36 documents/plan operations Supervision Internal Controls No/inadequate documentation of internal control environment Inadequate testing of allocations to Minor Item(s): participant accounts Participant Data & Participant Accounts Incomplete documentation of parties in Parties in Interest/Prohibited interest/related parties Transactions Subsequent Events Inadequate work Yes Full DC 401(k) Investments & 5 No testing of investment transactions 37 No testing of investment income Investment Transactions Parties in No documentation of results of inquiries Interest/Prohibited with management Transactions Commitments & No documentation of results of inquiries Contingencies with management No documentation of results of inquiries Subsequent Events with management Inadequate testing of Minor Item(s): eligibility/terminations/forfeitures Participant Data No 4 Limited DC 401(k) Planning & No/inadequate procedures on 38 initial/beginning balances Supervision Compliance with Inappropriate presentation of financial GAAS & GAAP information on financial statements Inadequate footnote disclosures Inadequate testing of allocations to Minor Item(s): participant accounts Participant Data & Inadequate testing of participant Participant investment options Accounts No documentation of parties in Parties in interest/related parties Interest/Prohibited Transactions 161

164 6-24 Plan Stratum # of EBPAQC Audit Plan Review # Audit Area(s) Detail of Findings Member Scope Findings Type 4 Limited DC 401(k) Planning & Conditions that affect the plan Yes 39 Supervision Preliminary analytics Notes Receivable No/inadequate testing of compliance with plan document Inadequate testing of reclassified distributions and loan documentation Contributions No test of timely remittance of employee contributions Received & Receivable No communication of delinquent remittances to management No work performed Commitments & Contingencies Yes 4 Limited DC 401(k) Planning & No planning analytical review 40 No documentation of significant Supervision decrease in net assets and large amount of benefit payments Internal Controls No documentation of activity level internal controls at plan sponsor level No/inadequate work regarding Minor Item(s): forfeitures Benefit Payments No documentation of consideration of partial plan termination which could have resulted in 100% vesting of participants Participant Data & No testing of compliance with compensation provisions Participant Relied on sponsor payroll for Accounts completeness and accuracy Yes No documentation of evalu ation of Limited DC 401(k) Internal Controls 4 41 internal control Investments & No/inadequate testing of change in service provider Investment Transactions Participant Data & No/inadequate testing of change in Participant service provider Accounts Inadequate testing of allocations to participant accounts No tax determination letter obtained Minor Item(s): Plan Tax Status Certifying entity does not q ualify for Investments & Yes 4 Limited DC 401(k) 42 limited scope Investment Transactions No test of timely remittance of employee Contributions Received & contributions Receivable No testing that contributions were received by the plan Inappropriate reliance on SOC1 report Benefit Payments No recalculation of benefit payments No/inadequate work regarding eligibility 162

165 6-24 Plan Stratum EBPAQC # of Audit Plan Audit Area(s) Detail of Findings Review # Type Findings Member Scope Participant Data & Inadequate testing of Participant eligibility/terminations/forfeitures Accounts No/insufficient testing of payroll data Inappropriate reliance on SOC1 report Limited DC 401(k) Investments & 4 Yes Certification is not for the plan 43 Certification obtained was for the master Investment trust Transactions Certification obtained from third party but third party is not a qualifying entity and is not an agent for the trustee/custodian Contributions Testing of employer matching contribution did not adequately address Received & the apparent failure by the sponsor the Receivable match the required 3% of compensation Compliance with Certification by third party of the ERISA & DOL Rules investments at the plan level is not supported by evidence of an Agency relationship between the third party and the trustee/custodian Testing of benefit payments was unclear Minor Item(s): as to specific procedures performed Benefit Payments No/inadequate documentation of internal Yes 4 Full DC Internal Controls 44 control environment Lack of documentation of risk assessment procedures No review of internal cont rol of service providers Investments & No testing of investment transactions Investment Inadequate documentation of confirmation of certain assets Transactions Participant Data & No/insufficient testing of payroll data No testing of compliance with Participant Accounts compensation provisions Inadequate testing of participant investment options Inadequate documentation regarding Minor Item(s): potential errors in profit sharing Contributions contribution Received & Receivable Inadequate footnote disclosures Compliance with Yes 3 Limited DC 401(k) 45 Reportable transaction schedule GAAS & GAAP presented but should not have one Reportable transaction schedule Minor Item(s): presented but should not have one Compliance with ERISA & DOL Rules No documentation of parties in Parties in interest/related parties Interest/Prohibited Transactions 163

166 6-24 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Member Scope Findings Type Yes No test of timely remittance of employee Full DC 401(k) Contributions 3 46 contributions Received & Receivable Inadequate testing of use of forfeitures Compliance with Inadequate footnote disclosures GAAS & GAAP Compliance with Delinquent employee contributions not ERISA & DOL Rules reported/disclosed No 3 Limited DC Planning & Insufficient audit programs 47 Inadequate planning analytics Supervision No evidence of required communications (114/115) Inadequate evidence of accuracy and Minor Item(s): propriety of withdrawals/in-service Benefit Payments partial withdrawals Participant Data & No/insufficient testing of payroll data Inadequate documentation of testing of Participant Accounts income allocations No testing of participant investment elections (SOC1 reliance) Unsigned IQPA report Compliance with Yes 3 Limited DC 401(k) 48 ERISA & DOL Rules No/inadequate evidence of fraud Minor Item(s): brainstorming"" Internal Controls Subsequent Events No review of interim financial data No/inadequate documentation of internal Yes 2 Limited DC 401(k) Internal Controls 49 control environment Contributions No test of timely remittance of employee Received & contributions Receivable Certifying entity does not qualify for Investments & Yes 2 Limited DC 401(k) 50 Investment limited scope Unsigned certification Transactions Participant Data & No/inadequate testing of change in service provider Participant Accounts No reconciliation of participant accounts to total assets No recalculation of employer and/or Contributions No 2 Limited DC 401(k) 51 employee contributions Received & Receivable No test of timely remittance of employee contributions No/insufficient testing of payroll data Participant Data & Participant Inappropriate reliance on SOC1 report Accounts Inadequate testing of participant investment options Inadequate testing of allocations to participant accounts 164

167 6-24 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type Yes 2 Limited DC 401(k) Participant Data & Inadequate testing of allocations to 52 Participant participant accounts Accounts Administrative Inadequate work Expenses Compliance with Yes DC 401(k) Limited Inadequate footnote disclosures 2 53 Inappropriate presentation of financial GAAS & GAAP information on financial statements No documentation of COSO (Committee Minor Item(s): of Sponsoring Organizations) controls at Internal Controls the plan sponsor Yes No review of internal control of service 2 Full DB Internal Controls 54 provider(s) Benefit Payments No/inadequate work regarding eligibility of individuals receiving benefits 2 Yes Limited DC Compliance with Inadequate footnote disclosures 55 GAAS & GAAP Compliance with Unsigned audit report ERISA & DOL Rules Limited No 2 DC 401(k) Participant Data & No/insufficient testing of payroll data 56 Participant Inappropriate reliance on SOC1 report Inadequate testing of allocations to Accounts participant accounts Inadequate testing of participant investment options No documentation of parties in Minor Item(s): interest/related parties Parties in Interest/Prohibited Transactions No 2 Limited 57 Participant Data & Inadequate testing of allocations to DC 401(k) Participant participant accounts Accounts Inadequate testing of participant investment options No work performed Parties in Interest/Prohibited Transactions Yes 1 Limited DC 401(k) Planning & No/inadequate procedures on 58 Supervision initial/beginning balances 165

168 6-24 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Type Member No/inadequate documentation of internal Yes 1 Limited DC 401(k) Internal Controls 59 control environment Contributions DC 1 Limited No documentation of recalculation of Yes 60 Received & employer match Receivable No recalculation of benefit payments Benefit Payments Yes 1 Limited DC 401(k) 61 No/inadequate work regarding eligibility of individuals receiving benefits No reconciliation of participant accounts Yes 1 F ull DC 401(k) Participant Data & 62 Participant to total assets Accounts Inadequate testing of allocations to participant accounts No recalculation of benefit payments Yes 1 Full Health Benefit Payments 63 No reconciliation of participant accounts Participant Data & Yes 1 Limited DC 401(k 64 Participant to total assets Accounts Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options 166

169 25-99 Plan Stratum # of EBPAQC Audit Plan Detail of Findings Review # Audit Area(s) Scope Findings Member Type 10 Limited DC Internal Controls No evidence of understanding of the Yes 1 plan's internal control environment at the cycle, account and transaction level No documentation of evaluation of internal control Investments per the trust report did not Investments & agree to the financial statements Investment No/lack of understanding of plan's Transactions common/collective trust and stable value fund investments No test of timely remittance of employee Contributions Received & contributions Inadequate testing of use of forfeitures Receivable Benefit Payments No/inadequate work regarding forfeitures Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of allocations to Accounts participant accounts Parties in No documentation of results of inquiries Interest/Prohibited with management Transactions No documentation of results of inquiries Commitments & Contingencies with management Inadequate footnote disclosures Compliance with GAAS & GAAP Incorrect FAS 157 fair value measurement disclosure Lack of documentation and Minor Item(s): understanding of loans rollover into the Notes Receivable plan Plan Tax Status No tax determination letter obtained Incorrect industry guide used resulting in Planning & No 10 Limited DC 401(k) 2 no identification of parties in interest Supervision No preliminary analytics performed No expectations developed Internal Controls Lack of documentation of risk assessment procedures No SOC1 report bridge letter No testing of complementary user controls No identification of significant audit areas Control risk assessments did not conform with actual level of work performed Parties in No work performed Interest/Prohibited No documentation of parties in Transactions interest/related parties No work performed Commitments & Contingencies 167

170 25-99 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member Administrative No work performed Expenses Subsequent Events No work performed Compliance with No/inadequate footnote disclosures ERISA & DOL Rules No testing of compliance with Minor Item(s): compensation provisions Participant Data & Participant Accounts Plan Tax Status No evidence IRS tax compliance tests were reviewed Compliance with Improper reporting of notes receivable GAAS & GAAP from participants No 9 DC Planning & No/insufficient audit program Limited 3 No/lack of evidence of audit planning Supervision 401(k) No evidence of required communications (114/115) No/insufficient review of plan documents/operation Notes Receivable No work performed No audit program for this area of audit Contributions No recalculation of employer and/or Received & employee contributions No schedule of contributions provided Receivable No test of timely remittance of employee contributions No testing of compliance with compensation provisions No/inadequate work regarding validity of Benefit Payments claims No schedule of benefits paid provided No recalculation of benefit payments No/inadequate work regarding eligibility No/insufficient testing of payroll data Participant Data & Participant Accounts Inadequate testing of eligibility/terminations/forfeiture Inadequate testing of participant investment options Inadequate documentation provided Parties in No documentation of parties in interest/related parties Interest/Prohibited Transactions No documentation of results of inquiries with management No work performed Plan Tax Status Administrative No work performed Expenses Representations not appropriately Plan Representations tailored to plan Inadequate representations 168

171 25-99 Plan Stratum EBPAQC Audit # of Plan Review # Audit Area(s) Detail of Findings Scope Findings Member Type 8 DC Internal Controls No/inadequate documentation of internal Yes Full 4 control environment No testing of investment transactions Investments & Inadequate testing of cost basis of non- Investment participant directed investments Transactions Contributions No recalculation of employer and/or Received & employee contributions No testing of compliance with Receivable compensation provisions Benefit Payments No recalculation of benefit payments Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of Accounts eligibility/terminations/forfeitures Parties in No disclosure of prohibited transactions Interest/Prohibited in notes to financial statements Transactions Inadequate work regarding transactions with plan sponsor - money going from plan to the sponsor Compliance with Inappropriate presentation of financial information on financial statements GAAS & GAAP Inadequate footnote disclosures Compliance with Required schedules no t attached/prepared ERISA & DOL Rules Yes 8 Full DC ESOP Internal Controls No/inadequate documentation of internal 5 control environment No/inadequate evidence of fraud inquiries No review of internal control of service providers Investments & No testing of assumptions or financial Investment data used in the valuation specialist's Transactions report No testing of investment transactions Insufficient testing of dividend income Participant Data & No/inadequate testing of change in Participant service provider No/insufficient testing of payroll data Accounts Inadequate testing of allocations to participant accounts Inadequate work Parties in Interest/Prohibited Transactions Inadequate documentation of inquiries Subsequent Events No review of subsequent plan amendments No indication whether receivables were subsequently received No modification in full scope unqualified Compliance with GAAS & GAAP report for material omission from the Schedule of Reportable Transactions 169

172 25-99 Plan Stratum EBPAQC Audit # of Plan Review # Detail of Findings Audit Area(s) Type Member Findings Scope Compliance with Schedule of Reportable Transactions did not include common stock shares ERISA & DOL Rules purchased from the officers of the sponsoring company Inadequate testing of the release of Minor Item(s): shares from unallocated to allocated Plan Obligations No assessment/review of specialist's assumptions Yes 7 DC 401(k) Planning & Limited No/insufficient audit program 6 No/insufficient review of plan Supervision documents/operation No evidence of required communications (114/115) Internal Controls No/inadequate documentation of internal control environment No documentation of evaluation of internal control No evidence of SOC1 Report review reliance Participant Data & No work performed Participant Accounts Parties in No work performed Interest/Prohibited Transactions Commitments & No work performed Contingencies Administrative No work performed Expenses No work performed Subsequent Events Internal Controls DB 7 Limited No assessment/documentation of control Yes 7 risk No evidence of SOC1 report review reliance No recalculation of benefit payments Benefit Payments Inadequate testing of Participant Data eligibility/terminations/forfeitures No testing of compliance with compensation provisions Inadequate testing of participant investment options No/insufficient testing of census data Plan Obligations Plan Tax Status No work performed No work performed Administrative Expenses 170

173 25-99 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member No documentation of parties in Minor Item(s): interest/related parties Parties in No documentation of results of Interest/Prohibited inquiries with management Transactions Yes 7 Limited DC 401(k) Planning & No/insufficient review of plan 8 Supervision documents/plan operations No evidence of required communications (114/115) No calculation of audit materiality No evidence of preliminary analytics No documentation of prior year known issues Investments & Certification did not include asset listing and transactions certified Investment Transactions Inadequate documentation as to source Notes Receivable of listings for completeness and accuracy Inadequate consideration of error in loan reporting on the financial statements Inadequate reconciliation of receivable - Contributions Received & audit workpapers were on the cash Receivable basis but the financial statements were on the accrual basis Inadequate consideration of the impact of non-correction of prior year errors on the current year work & financial statements No/insufficient testing of payroll data Minor Item(s): Inadequate testing of participant Participant Data & investment options Participant Accounts Compliance with IQPA report not modified for lack of GAAS & GAAP ERISA required schedules Inadequate footnote disclosures Compliance with Required schedules not attached/prepared ERISA & DOL Rules 5 Full DB Investments & No Inappropriate reliance on SOC1 report 9 No testing of investment transactions Investment Transactions No testing of investment income No evidence of testing of participant Participant Data data provided to the plan's actuary Plan Obligations No/insufficient testing of census data No evidence of testing of plan's funding status 171

174 25-99 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member Parties in No documentation of parties in Interest/Prohibited interest/related parties Transactions No documentation of results of inquiries with management Compliance with Incomplete IQPA report attached to ERISA & DOL Rules Form 5500 Yes 5 Limited DC 401(k) Internal Controls Failure to document COSO (Committee 10 of Sponsoring Organizations) controls Parties in No documentation of parties in interest/related parties Interest/Prohibited No documentation of results of Transactions inquiries with management Compliance with Inadequate footnote disclosures IQPA report did not refer to GAAS & GAAP supplemental information Inadequate work Minor Item(s): No documentation of results of Commitments & inquiries with management Contingencies Subsequent Events Yes Limited DC 401(k) Planning & No evidence of required 5 11 Supervision communications (114/115) No evidence of materiality Insufficient analytics Unsigned plan adoption agreement and participant agreements No/insufficient testing of payroll data Participant Data & Participant Inadequate testing of participant deferral percentage Accounts No evidence of recalculation of deferral percentage Inappropriate presentation of financial Compliance with GAAS & GAAP information on financial statements Schedule H, Line 3, audit opinion type Compliance with ERISA & DOL Rules not properly completed Inadequate testing of rollover Minor Item(s): distributions Benefit Payments No listing of benefit payments No recalculation of employer and/or Yes 5 Limited DC 401(k) Contributions 12 Received & employee contributions Receivable Lack of documentation of risk Minor Item(s): assessment procedures Internal Controls No/inadequate evidence of fraud "brainstorming" No review of internal control of service providers No understanding & review of internal control over payroll service provider 172

175 25-99 Plan Stratum EBPAQC # of Plan Audit Review # Detail of Findings Audit Area(s) Findings Type Member Scope Participant Data & No/insufficient testing of payroll data No documentation supporting change Participant Accounts in scope of testing of 5 participants to 1 for income allocation and investment election testing Compliance with IQPA report not modified for lack of GAAS & GAAP ERISA required schedules Improper reference to certifying entity GIC valuation methodology incorrect Schedule of assets indicates wrong class of fund for an investment Missing information on schedule of assets related to participant loans Missing schedule of reportable transactions Compliance with Required schedules not ERISA & DOL Rules attached/prepared No 5 DC 401(k) Planning & No/insufficient review of plan Limited 13 Supervision documents/plan operations No documentation of parties in Minor Item(s): interest/related parties Parties in Interest/Prohibited Transactions Plan Tax Status No evidence IRS tax compliance tests were reviewed Subsequent Events No review of interim financial data Compliance with Opinion and footnotes refer to GAAS & GAAP incorrect trustee/custodian related to the limited scope audit Inadequate evidence obtained of Yes 5 Limited DC 401(k) Participant Data 14 transfer of $2.3M to an affiliated entity benefit plan No testing of the payroll process Inadequate documentation of Minor Item(s): preliminary expectations Planning & Inadequate identification and Supervision documentation of $2.3M unusual and infrequent transaction No/inadequate documentation of Internal Controls internal control environment No evidence of SOC1 report review reliance of sponsor payroll provider Inadequate documentation of walk- throughs Inappropriate reliance on SOC1 report Contributions Received & Did not test integrity of payroll Receivable system 173

176 25-99 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Type Scope Findings Member Compliance with Audit report did not extend to schedule of delinquent contributions ERISA & DOL Rules 4 Limited DC 401(k) Internal Controls No/inadequate documentation of Yes 15 internal control environment No assessment/documentation of control risk No/inadequate evidence of fraud "brainstorming" No evidence of SOC1 report review reliance No testing of compliance with Participant Data & Participant compensation provisions Accounts No recalculation of employee contributions Inadequate testing of participant investment options No reconciliation of participant accounts to total assets Parties in No work performed No documentation of parties in Interest/Prohibited Transactions interest/related parties No planning to address risks in change Minor Item(s): of trustee & recordkeepers at mid-year Planning & No evidence of workpaper review Supervision Internal Controls 4 Limited DC 401(k) Yes No documentation of evaluation of 16 internal control No identification and review of user controls of third party service providers Participant Data & No/insufficient testing of payroll data Inadequate testing of Participant Accounts eligibility/terminations/ forfeitures Inadequate testing of allocations to participant accounts Inadequate testing of participant investment options Detail tests of data samples incomplete Inadequate preliminary review Minor Item(s): Inadequate risk assessment process Planning & Supervision Contributions No/inadequate documentation of Received & testing of employer contributions and Receivable employee deferrals to an accurate posting to individual participant accounts No planning analytics with developed Planning & Yes 4 Limited DC 401(k) 17 Supervision expectations No materiality workpaper No evidence of required communications (114/115) 174

177 25-99 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Findings Type Scope Member No assessment/documentation of Internal Controls control risk No/insufficient testing of payroll data Participant Data & Participant Accounts Inadequate work Minor Item(s): Plan Tax Status Lack of documentation of risk Yes 4 Limited DC 401(k) Internal Controls 18 assessment procedures Parties in No work performed Interest/Prohibited Transactions Plan No plan representation letter Representations No review of interim financial data Minor Item(s): No audit program for this area of audit Subsequent Events for this area of audit Internal Controls DC 401(k) Yes 4 Limited No review of internal control of service 19 providers No/inadequate evidence of fraud "brainstorming" Contributions No recalculation of employer and/or Received & employee contributions Receivable Participant Data & No/insufficient testing of payroll data Participant No testing of participant opening balances audited by another auditor Accounts No documentation of parties in interest Minor Item(s): Parties in Interest/Prohibited Transactions No evidence of SOC1 report review No 4 Full DC Internal Controls 20 reliance Participant Data & Inadequate testing of allocations to Participant participant accounts Accounts Parties in Inadequate work Interest/Prohibited Transactions Inadequate footnote disclosures Minor Item(s): Compliance with GAAS & GAAP Yes 3 Limited DB cash Plan Obligations No/insufficient testing of census data 21 balance No/insufficient testing of payroll data Minor Item(s): Participant Data & Participant Accounts 175

178 25-99 Plan Stratum EBPAQC # of Audit Plan Review # Detail of Findings Audit Area(s) Scope Findings Type Member Plan Tax Status No evidence IRS tax compliance tests were reviewed Investments & DC 401(A) 3 Limited Certifying entity does not qualify for Yes 22 Investment limited scope Transactions No/insufficient testing of payroll data Minor Item(s): Participant Data Compliance with Opinion is incorrectly dated to prior GAAS & GAAP year Inappropriate reliance on SSAE 16 to Internal Controls Yes 3 Limited DC 401(k) 23 assess risk in significant audit areas No/insufficient testing of payroll data Participant Data & Participant Accounts Inadequate work Parties in Interest/Prohibited Transactions 3 Full Health Investments & Yes Inappropriate reliance on SOC1 report 24 No testing of end of year asset values Investment No testing of investment transactions Transactions No testing of investment income No evidence of SOC1 report review Minor Item(s): reliance Internal Controls Parties in No work performed Interest/Prohibited Transactions Yes 2 Certification does not mention plan Limited DC Investments & 25 Investment name nor period covered Transactions Participant Data & No/insufficient testing of payroll data Participant Inadequate testing of allocations to participant accounts Accounts Yes 1 Limited DC 401(k) Planning & No/inadequate procedures on 26 Supervision initial/beginning balances Yes 1 Full DC 401(k) Investments & No verification of existence of plan 27 Investment assets with the custodian Transactions Complete reliance on account statement 176

179 100-749 Plan Stratum EBPAQC # of Plan Audit Audit Area(s) Detail of Findings Review # Scope Findings Member Type Yes 8 Limited Health Planning & No/insufficient review of plan 1 Supervision documents/plan operations Benefit Payments No recalculation of benefit payments No/inadequate work regarding validity of claims Plan Obligations No assessment of whether actuary used plan's provisions and considered the plan's amendment effective 1/1/2011 No test of timely remittance of Minor Item(s): employee contributions Contributions Received & Receivable Parties in Incomplete documentation of inquiries Interest/Prohibited with management (with whom, when) Transactions No documentation of parties in interest/related parties No tax determination letter obtained Plan Tax Status Commitments & No documentation of results of Contingencies inquiries with management Subsequent Events No documentation of results of inquiries with management Yes 4 Limited DB Benefit Payments No recalculation of benefit payments 2 No agreement of benefit payment recalculations for compliance with formula in the plan document Participant Data No/insufficient testing of payroll data No testing of compliance with compensation provisions Inadequate testing of eligibility/terminations/ forfeitures No/insufficient testing of census data Plan Obligations Administrative No work performed Expenses No testing of plan assets transferred at Plan Mergers & Yes 1 Limited DC 401(k) 3 Terminating Plans 12/31/11 to another plan at the detailed participant level until 2013 177

180 750 + Plan Stratum # of Audit EBPAQC Plan Review # Audit Area(s) Detail of Findings Type Scope Findings Member Yes Limited DB Internal Controls No/inadequate documentation of 5 1 internal control environment Possible fraud discussed in board minutes but engagement team did not inquire of legal counsel or include it is a fraud risk factor Contributions IQPA did not identify or inquire about Received & potential missing contributions Receivable occurring in time period leading up to plan administrator's termination and his possible conversion, fraud and theft No agreement of contributions to actuarial report No/insufficient testing of payroll data Participant Data No/insufficient testing of census data Plan Obligations No legal representation letter obtained Minor Item(s): Commitments & Contingencies Planning & Yes 2 Full DC No/inadequate procedures on 2 Supervision initial/beginning balances No/insufficient review of plan documents/operations Inadequate testing of Minor Item(s): eligibility/terminations/ forfeitures Participant Data & Participant Accounts Inadequate work, overall conclusion of Yes 1 Limited DC 401(k) Parties in 3 Interest/Prohibited no non-exempt transactions was not Transactions supported by evidence of procedures performed Relevant portion of audit program was not completed No documentation of parties in interest/related parties 178

181 Appendix IV - Listing of De ficient Audits and Peer Review Information 1-2 Plan Stratum # of Year State Number Type of Member Peer Peer Audit Peer State Plan Review Became of Times IQPA Review Review Review of the Society Areas Audit EBPAQC Type Located Plan Number Opinion Engagement Performed EBPQAC Member with Year Audited In member Findings Limited- 15 DC No Yes Yes 2012 Pass GA 2 to 3 1 times Scope Audit Limited- No DC No No 15 OH Not 2 Licensed Response Scope Audit Response Full-Scope No DC 15 No No CA 1 time 3 Audit 15 Limited- 2 to 3 DC No Yes Yes 2012 Pass GA 4 Scope Audit times 15 Full-Scope No DC No No NY Not 5 Licensed Audit Response Response Yes Limited- DC First time 14 2013 No TX 2012 Pass Yes 6 Scope Audit 403b audited 14 Limited- No DC No No PA Not 7 Licensed Response Scope Audit Response 14 Full-Scope No DC No No NY Fail Yes 2013 8 Audit Response Response 14 Limited- CA DC No Yes Yes 2012 Pass 4 or more 9 times Scope Audit Yes 13 1 time DC OK Pass Full-Scope Yes 2012 No 10 403b Audit AR 13 Full-Scope DC No No No No 11 Response Response Audit 2012 Full-Scope Yes Yes No Pass with 13 IA 4 or more HW 12 times Audit deficiencies No No No 13 NY No Other DC 13 Response Response 12 Limited- DC No Yes Yes 2012 Pass MA 4 or more 14 times Scope Audit Limited- TX DC No 12 Yes Yes 2011 Pass with 4 or more 15 deficiencies Scope Audit times Limited- No 12 No DC NY 4 or more No 16 Scope Audit times Yes 12 4 or more DC No Yes Limited- 2012 Pass NY 17 Scope Audit times 2 to 3 12 Full-Scope IL DC No Yes Yes 2012 Pass 18 Audit times 12 No Limited- DC No No GA No 19 Response Scope Audit Response 11 Limited- 4 or more DC No Yes Yes 2011 Pass CT 20 Scope Audit times First time 11 Limited- NY DC No Yes Yes 2011 Pass 21 Scope Audit audited 4 or more 11 Limited- NY DC No No No 22 Scope Audit times 4 or more 10 Limited- HI DC No Yes Yes 2011 Pass 23 Scope Audit times 4 or more Pass with 10 Full-Scope DC No Yes Yes 2013 OH 24 times deficiencies Audit 179

182 1-2 Plan Stratum # of Number State Year Member Peer Type of Peer Peer State Audit Became Plan IQPA Review of Times Review Society Areas Review of the Audit Review Number Plan EBPAQC Located Type EBPQAC Opinion Performed with Engagement Year Member In Audited member Findings 10 Full-Scope Pass DC No Yes Yes 2011 2 to 3 NC 25 times Audit 2011 10 DC No Yes Yes 4 or more Pass VT Limited- 26 Scope Audit times 10 Full-Scope CA HW No No Yes Pass No 2011 27 Response Response Audit 10 No DC No IL No Pass Full-Scope Yes 2010 28 Response Audit Response 4 or more 10 Limited- PA DC No Yes No 29 Scope Audit times 9 Limited- DC No Yes No - firm 1 time CA 30 Scope Audit dissolved 9 Full-Scope CT DC No Yes First time 2011 Pass with Yes 31 deficiencies audited Audit Yes 9 2 to 3 DC NY Yes Full-Scope 2013 Pass No 32 Audit times 4 or more 9 Limited- NJ DC No Yes Yes 2012 Pass 33 Scope Audit times Yes 9 4 or more DC No NC Yes Limited- 2010 Pass 34 Scope Audit times 4 or more 8 Full-Scope NY DC No Yes Yes 2013 Pass 35 Audit times MO 8 Limited- DC 4 or more Yes Yes 2012 Pass No 36 Scope Audit times No Limited- 7 No DC No MA Yes 2012 Pass 37 Response 403b Response Scope Audit Limited- Yes DC 2 to 3 Yes 2011 7 Yes 2012 Pass AL 38 403b times Scope Audit 2011 Limited- DC No 7 Yes 4 or more Pass with CA Yes 39 deficiencies Scope Audit times 7 Limited- First time DC Yes 2011 Yes Yes 20111 Pass CA 40 Scope Audit audited 2011 Limited- DC No 7 Yes 4 or more Pass SC Yes 41 Scope Audit times 7 Limited- First time DC No Yes Yes 2012 Pass with AZ 42 deficiencies audited Scope Audit 7 Limited- AL DC No Pass Yes Yes 2011 4 or more 43 Scope Audit times 4 or more 6 Limited- VA DC No Yes Yes 2010 Pass 44 Scope Audit times 6 No Yes No DC NJ 2 to 3 Limited- 45 Scope Audit times No 6 1 time DC No Limited- Yes 2011 Pass CA 46 Scope Audit 4 or more 5 Limited- WA DC Yes 2002 Yes Yes 2011 Pass 47 Scope Audit times Yes 5 First time DC No MD Yes Limited- 2012 Pass 48 Scope Audit audited 1 time 5 Limited- MI DC No No Yes 2011 Pass 49 Scope Audit 4 or more 5 Limited- WA DC No Yes Yes 2011 Pass 50 Scope Audit times 4 or more 5 Limited- DC No No No CA 51 times Scope Audit 180

183 1-2 Plan Stratum # of Year State Number of Type of Audit Peer Peer Member Peer State Plan IQPA Review Became Society Areas Times Plan of the Review Review Audit Review Type Number EBPAQC Locat Engagement Year EBPQAC Performed Opinion with Member Audited member ed In Findings 5 Limited- 4 or more DC No Yes Yes 2011 Pass CO 52 Scope Audit times 5 Full-Scope 4 or more DC No Yes Yes 2013 Pass IL 53 Audit times 4 Limited- DC No 4 or more Yes Yes 2011 Pass with KS 54 deficiencies Scope Audit times Yes 4 DC No Limited- Yes 2012 Pass GA 55 Scope Audit No Limited- 4 or more DC No 4 Yes 2011 Pass TX 56 Scope Audit times No 4 Limited- CA DC No No Pass 2011 Yes 57 Scope Audit Response Response No 4 Limited- ID DC Yes No Pass No 2013 Yes 58 Response Scope Audit Response Response 4 or more 3 Limited- NY DC No No Yes 2011 Pass with 59 deficiencies Scope Audit times Pass 4 or more 3 Limited- VA DC Yes 2009 Yes Yes 2011 60 Scope Audit times 2012 3 No Yes Yes DC Pass with TX 2 to 3 Limited- 61 times deficiencies Scope Audit Yes 3 4 or more DC No Yes Limited- 2011 Pass RI 62 Scope Audit times 2 to 3 3 Limited- CO DC No Yes Yes 2012 Pass 63 Scope Audit times Yes 3 DC No 4 or more Yes Full-Scope 2013 Pass CO 64 times Audit 3 No DC No No Limited- Yes 2010 Pass CA 65 Scope Audit Response Response Yes 1 time 3 Limited- NY DC No Yes Pass 2009 66 Scope Audit Pass DC No Yes Limited- No IN 4 or more 2 2010 67 times Scope Audit Yes Full-Scope DB Yes 2010 2 Yes 2012 Pass OR 2 to 3 68 times Audit No 2 Limited- CA DC Pass Yes Yes 2010 4 or more 69 Scope Audit times 1 time 2 Limited- MI DC No Yes Yes 2013 Pass 70 Scope Audit 4 or more 1 Limited- NY DC No Yes Yes 2013 Pass 71 Scope Audit times 4 or more Pass 1 Limited- DC No Yes Yes 2013 TX 72 times Scope Audit 181

184 3-5 Plan Stratum # of State Number Year Type of Peer Member Peer Peer Audit State Review Plan of Times Became IQPA Society of the Review Review Review Audit Areas Number Located EBPAQC Type Plan Engagement EBPQAC Year Opinion Performed with Member Audited In member Findings Full-Scope TX DC No Yes Yes 2012 Pass 15 4 or more 1 times Audit Limited- DC No 13 Yes Yes 2010 Pass with 4 or more IL 2 deficiencies Scope Audit times Full-Scope Yes HW No Yes 13 2011 Pass AR 2 to 3 3 times Audit Limited- 13 DC No No No CA Yes 2011 Pass with 4 deficiency Response Response Scope Audit 13 Limited- AL DC No 2 to 3 Yes 2011 Pass Yes 5 times Scope Audit 12 Full-Scope DB Yes 2013 No Yes 2011 Pass TX 4 or more 6 times Audit Limited- 2012 DC No Yes Yes 12 Pass FL First time 7 audited Scope Audit Limited- 11 DC 2 to 3 No NC Yes 2012 Pass No 8 403b times Scope Audit 11 Full-Scope TX DC No Yes 4 or more 2012 Pass Yes 9 times Audit 2012 11 HW No Yes Yes 4 or more Pass Full-Scope 10 Audit times 11 Limited- PA DC Yes No Pass 4 or more Yes 2013 Yes 11 Response times Scope Audit Yes 11 4 or more DC MA Yes Limited- 2011 Pass No 12 Scope Audit times GA 11 Limited- No DC Yes Yes 2013 Pass 4 or more 13 times Scope Audit Yes Limited- 10 No DC Yes 2012 Pass AR 2 to 3 14 times 403b Scope Audit Limited- Yes DC 1 time No 10 Yes 2012 Pass TX 15 403b Scope Audit Limited- Yes DC No 10 Yes 2011 Pass MI 4 or more 16 times Scope Audit 9 Limited- 4 or more DC No Yes Yes 2013 Pass TX 17 Scope Audit times Limited- TX DC Yes No 9 No No Pass Yes 2011 18 Response Response Response Scope Audit Limited- 2011 9 Yes No No No GA Pass Yes DC 19 Response Response Response Scope Audit No 9 Limited- NY DC No Pass No 2010 Yes 20 Response Response Scope Audit 9 No Limited- DC No No MA Pass Yes 2011 21 Response Scope Audit Response 9 Full-Scope FL DC No No No Pass 2010 Yes 22 Response Audit Response 4 or more 9 Full-Scope WA DC No Yes Yes 2013 Pass 23 Audit times Yes 8 4 or more DC No PA Yes Limited- 2013 Pass 24 Scope Audit times 4 or more 7 Limited- FL DC No Yes Yes 2011 Pass with 25 deficiencies times Scope Audit 4 or more 7 Limited- FL DC No No Yes 2011 Pass with 26 deficiencies Scope Audit times 2 to 3 Pass with 6 Limited- DC Yes 2007 Yes Yes 2012 AZ 27 times 403b deficiencies Scope Audit 182

185 3-5 Plan Stratum # of Number Year State Member Type of Peer Peer State Audit Peer Became Review IQPA of Times Plan Review Society Areas Review of the Audit Review Number Plan EBPAQC Located Type EBPQAC Opinion Performed with Engagement Year Member In Audited member Findings 6 Limited- UT DC No No Yes 1 time Pass 2012 28 Scope Audit 2013 6 DC Yes 2012 Yes Yes 4 or more Pass TX Limited- 29 Scope Audit times 5 Limited- NY DC No Yes 4 or more 2012 Pass Yes 30 times Scope Audit Yes 5 First time DC No AR Yes Limited- 2012 Pass 31 Scope Audit audited 4 or more 5 Limited- NC DC No Yes Yes 2013 Pass 32 Scope Audit times 2011 5 DC No Yes Yes 4 or more Pass UT Limited- 33 Scope Audit times 5 Full-Scope MD DB No No 4 or more 2010 Pass Yes 34 times Audit Yes 5 4 or more DC No NE Yes Limited- 2010 Pass 35 Scope Audit times 4 or more 5 Full-Scope AR HW No Yes Yes 2013 Pass 36 Audit times Yes 5 4 or more DC Yes TX Yes Limited- 2013 Pass 2013 37 Scope Audit times 2 to 3 5 Limited- AR DC No Yes Yes 2011 Pass 38 Scope Audit times 5 Limited- DC Yes No PA No Yes 2012 Pass No 39 Response Response Scope Audit Response HW 4 or more 5 Limited- NH No Yes No 40 Scope Audit times 2011 DC No 4 No Limited- No Yes Yes Pass OH 41 Response Response Response Scope Audit No DC No 4 No Limited- Yes 2013 Pass with KY 42 deficiencies Response Scope Audit Response Pass DC 2010 Limited- Yes 2012 Yes CA 2 to 3 4 Yes 43 times Scope Audit Limited- DC 4 No No Yes 2006 Pass, but 4 or more CA 44 review not times Scope Audit w/n 3 yr. period Limited- Yes DC No 4 Yes 2011 Pass OH First time 45 Scope Audit audited Yes Limited- DC 4 No 1 time Yes NC 2013 Pass 46 Scope Audit 403b 4 Limited- Yes DC Yes 2011 Yes NJ 2012 Pass 1 time 47 Scope Audit Yes Limited- DC No No 4 No NY 2010 Pass 48 Scope Audit Response Response 3 Limited- 2 to 3 DC Yes No AZ Yes Yes 2012 Pass 49 Response times Scope Audit 3 Full-Scope 4 or more HW No Yes Yes 2011 Pass MA 50 Audit times 3 Limited- No DC Yes No No Pass 2014 MA 51 403b Scope Audit Response Response 4 or more 3 Limited- OH DC No Yes Yes 2011 Pass 52 Scope Audit times 2 to 3 3 Limited- VA DC No Yes Yes 2010 Pass 53 Scope Audit times 4 or more Pass 3 Limited- DC No No Yes 2011 CA 54 times Scope Audit 183

186 3-5 Plan Stratum # of State Number Year Type of Peer Member Peer Peer Audit State Review Plan of Times Became IQPA Review Society Areas Audit Review Review of the Located Type EBPAQC Number Plan Opinion Engagement Member EBPQAC Performed Year with Audited In member Findings 3 Limited- NY DC Pass with No No 2 to 3 2012 Yes 55 Scope Audit 403b times deficiencies 2011 2 DC No Yes Yes First time Pass ID Limited- 56 Scope Audit audited 2 Full-Scope TN HW No No 4 or more 2011 Pass Yes 57 times Audit Yes 2 4 or more DC No KY Yes Full-Scope 2010 Pass 58 Audit times 4 or more 2 Limited- DC No Yes Yes 2012 Pass NJ 59 times Scope Audit Yes 2 No Yes DC 2011 Pass IN 4 or more Limited- 60 times Scope Audit No 2 HW Yes No Full-Scope Yes 2012 Pass KS No 61 Response Response Response Audit 2008 2 Limited- NC DC Yes 4 or more Yes Yes 2012 Pass 62 Scope Audit times Yes 1 DB Yes 4 or more Yes Full-Scope 2012 Pass NY 2013 63 times Audit 1 No DC No No Limited- Yes 2013 NY 64 Scope Audit Response Response No 1 Full-Scope DB No No Yes 2012 IL 65 Audit Response Response 184

187 6-24 Plan Stratum # of State Number Year Type of Peer Member Peer Peer Audit State Review Plan of Times Became IQPA Society of the Review Review Review Audit Areas EBPAQC Located Number Type Plan Engagement EBPQAC Year Opinion Performed with Member Audited In member Findings Full-Scope First time DC Yes 2014 No Yes 2012 Pass WA 13 1 audited Audit 2012 Limited- No No Yes DC Pass FL No 13 2 Response Response Scope Audit 403b Yes Limited- DC Yes 2008 Yes 11 2012 Pass NJ 1 time 3 Scope Audit 11 Limited- 4 or more DC No Yes Yes 2012 Pass KY 4 Scope Audit times Yes 11 No Yes DC 2012 Pass MI 4 or more Limited- 5 Scope Audit times Yes Limited- DB Yes 2014 No 10 2012 Pass WA 4 or more 6 times Scope Audit 10 Limited- 4 or more DC Yes 2010 Yes Yes 2011 Pass TX 7 Scope Audit times Limited- First time DC No 10 Yes Yes 2012 Pass MI 8 audited Scope Audit 10 Limited- 4 or more DC Yes 2014 No Yes 2012 Pass WA 9 Scope Audit times Yes 9 DC No No No Limited- 2012 Pass FL 10 Response Scope Audit Response Yes 2 to 3 Full-Scope PA DC 9 2009 Yes Yes 2010 Pass 11 Audit times 2012 9 DC Yes 2008 Yes Yes First time Pass AK Limited- 12 Scope Audit audited 9 Limited- No dc No No FL Yes 2012 Pass 13 Response Scope Audit Response First time 8 Limited- TX DC Yes 2010 Yes Yes 2011 Pass 14 Scope Audit audited Yes 8 DC Yes 4 or more Yes Full-Scope 2012 Pass CT 2008 15 times Audit Yes 2007 2 to 3 DC MN Limited- 8 Yes Yes 2010 Pass 16 403b Scope Audit times NJ 4 or more 8 Limited- Pass DC Yes 2008 Yes Yes 2012 17 Scope Audit times 1 time 8 Limited- MN DC Pass Yes 2007 Yes Yes 2010 18 403b Scope Audit 4 or more 8 Limited- OH DC No Yes Yes 2013 Pass 19 Scope Audit times NJ 4 or more 8 Limited- Pass DC Yes 2008 Yes Yes 2012 20 Scope Audit times 2 to 3 8 Limited- KY DC Pass No Yes Yes 2012 21 403b times Scope Audit FL 8 Limited- DC No No Yes 2012 Pass No 22 Response Scope Audit Response 2 to 3 7 Limited- DC No Pass Yes Yes 2012 KY 23 times Scope Audit 185

188 6-24 Plan Stratum # of Number State Year Type of Peer Peer State Audit Member Peer Review Became of Times IQPA Plan of the Society Review Areas Review Audit Review Number Type Located EBPAQC Plan Engagement Performed Member EBPQAC with Opinion Year Audited member In Findings Limited- 4 or more DC Yes 2014 No Yes 2012 Pass 7 WA 24 Scope Audit times Pass Limited- Yes 2014 No Yes 2012 DB WA 4 or more 6 25 times Scope Audit Limited- 1 time DC Yes 2008 Yes Yes 6 Pass IA 2013 26 Scope Audit Pass with Full-Scope DC Yes 2006 Yes 6 2010 4 or more CA Yes 27 deficiencies Audit times 6 Limited- 2010 DC Yes 2006 Yes Yes 4 or more Pass with CA 28 Scope Audit times deficiencies Limited- 6 No No DC Yes 2012 Pass FL No 29 Response Scope Audit Response Limited- 6 HW Yes 2008 4 or more Yes 2012 Pass NJ Yes 30 times Scope Audit 6 Limited- 2 to 3 DC MN Yes 2007 Yes Yes 2013 Pass 31 403b Scope Audit times Limited- 2 to 3 DC 6 2007 Yes Yes 2011 Pass CA Yes 32 times Scope Audit 5 Limited- 4 or more DC No Yes Yes 2012 Pass MI 33 Scope Audit times 5 Limited- 4 or more DC Yes 2009 No Yes 2010 Pass PA 34 Scope Audit times 2 to 3 5 Limited- KY DC Pass No Yes Yes 2011 35 403b Scope Audit times Limited- 2 to 3 5 CA DC Yes 2007 Yes Yes 2011 Pass 36 Scope Audit times 5 Full-Scope DC Yes 2008 Yes Yes 2013 Pass IA 4 or more 37 times Audit Limited- Yes DC No Yes 4 2013 Pass OH First time 38 audited Scope Audit Limited- Yes DC Yes 2010 4 Yes 2011 Pass TX 1 time 39 Scope Audit 4 Limited- CT DC Yes 2008 2 to 3 Yes 2012 Pass Yes 40 times Scope Audit 2011 4 DC Yes 2007 Yes Yes First time Pass CA Limited- 41 Scope Audit audited 4 Limited- IA DC Yes 2008 4 or more Yes 2013 Pass Yes 42 times Scope Audit Yes 4 DC Yes 4 or more Yes Limited- 2013 Pass IA 2008 43 times Scope Audit Yes 4 DC Yes 2008 Full-Scope Yes 2012 Pass CT 4 or more 44 times Audit 3 Limited- First time DC Yes 2008 Yes Yes 2012 Pass AK 45 Scope Audit audited 3 Full-Scope 2 to 3 DC Yes 2009 Yes Yes 2011 Pass MS 46 Audit times 4 or more 3 Limited- OH DC No Yes Yes 2013 Pass 47 Scope Audit times Yes 3 4 or more DC Yes FL Yes Limited- 2013 Pass 2004 48 Scope Audit times 4 or more 2 Limited- PA DC Yes 2009 No Yes 2010 Pass 49 Scope Audit times 4 or more 2 Limited- PA DC Yes 2009 No Yes 2010 Pass 50 Scope Audit times 1 time MI Pass 2 Limited- 2012 DC No Yes Yes 51 Scope Audit 186

189 6-24 Plan Stratum # of State Number Year Member Type of Peer Audit State Peer Peer Plan IQPA Became Review of Times Society Review Review of the Audit Areas Review Located Type Plan EBPAQC Number Performed Year Member Opinion EBPQAC with Engagement Audited member In Findings 2 Limited- MS DC Yes 4 or more Yes Yes 2011 Pass 2009 52 Scope Audit times 4 or more 2 Limited- CA DC Yes 2007 Yes Yes 2011 Pass 53 Scope Audit times Yes 2 2 to 3 DB Yes MN Yes Full-Scope 2013 Pass 2007 54 Audit times 4 or more 2 Limited- FL DC Yes 2004 Yes Yes 2013 Pass 55 Scope Audit times 4 or more 2 Limited- MI DC No Yes Yes 2012 Pass 56 Scope Audit times 2 4 or more Limited- OH Pass DC No Yes Yes 2013 57 Scope Audit times Yes 1 First time DC Yes TX Yes Limited- 2011 Pass 2010 58 Scope Audit audited 4 or more 1 Limited- IA DC Yes 2008 Yes Yes 2013 Pass 59 Scope Audit times 2 to 3 1 Limited- CA DC Yes 2006 Yes Yes 2010 Pass with 60 deficiencies Scope Audit times DC First time 1 Limited- CA Pass with Yes 2006 Yes Yes 2010 61 deficiencies audited Scope Audit 1 Full-Scope TX DC Yes 2 to 3 Pass Yes Yes 2011 No 62 Response Audit times 4 or more 1 Full-Scope CT HW Yes 2008 Yes Yes 202 Pass 63 Audit times 4 or more Pass 1 Limited- DC Yes 2007 Yes Yes 2011 CA 64 times Scope Audit 187

190 25-99 Plan Stratum # of Number State Year of Type of Peer Peer Peer State Member Audit Review IQPA Plan Became of the Society Times Review Areas Audit Review Review Type EBPAQC Located Number Opinion Engagement EBPQAC Year Plan with Member Performed In member Audited Findings 2012 Limited- Yes 2007 10 Yes DC Pass NY 4 or Yes 1 Scope Audit more times 2011 10 DC No Yes Yes Limited- Pass MD 4 or 2 more Scope Audit times 9 Limited- 4 or DC No Yes Yes 2011 Pass MD 3 Scope Audit more times Pass DC Yes 2006 Yes Yes 2012 Full-Scope IL 4 or 8 4 more Audit times Full-Scope 8 DC Yes 2004 Yes Yes 2011 Pass VA 4 or 5 more Audit times 7 Limited- First DC Yes 2006 Yes Yes 2012 Pass AZ 6 Scope Audit time audited Limited- IL DB Yes No 1 time Yes Yes 2012 Pass 7 7 Response Scope Audit Limited- 4 or DC Yes 7 Yes Yes 2011 Pass VA 2007 8 more Scope Audit times DB 5 Full-Scope MD Pass No Yes Yes 2011 1 time 9 Audit Pass Limited- Yes 2006 Yes Yes 2012 DC AZ 4 or 5 10 more Scope Audit times Limited- 4 or DC Yes 2007 Yes 5 2011 Pass VA Yes 11 Scope Audit more times Yes DC Yes 5 Yes Limited- 2011 Pass CA 2 to 3 2008 12 Scope Audit times 2011 5 DC No Yes Yes 4 or Pass MD Limited- 13 Scope Audit more times 5 Limited- 4 or DC Yes 2008 Yes Yes 2011 Pass CA 14 Scope Audit more times 4 Limited- 1 time DC AZ 2006 Yes Yes 2012 Pass Yes 15 Scope Audit Yes 4 DC Yes 2007 Limited- Yes 2012 Pass NY 4 or 16 more Scope Audit times 4 Limited- 2 to 3 DC Yes 2007 Yes Yes 2011 Pass VA 17 Scope Audit times 2 to 3 4 Limited- AZ DC Yes 2006 Yes Yes 2012 Pass 18 Scope Audit times 1 time 4 Limited- CA DC Yes 2008 Yes Yes 2011 Pass 19 Scope Audit MD 4 Full-Scope Pass DC 1 time Yes Yes 2011 No 20 Audit 4 or VA 3 Limited- Pass DB Yes 2004 Yes Yes 2011 21 Scope Audit more times 188

191 25-99 Plan Stratum # of State Number Year Type of Peer Member Peer Peer Audit State IQPA Plan of Times Became Review Review of the Review Society Review Audit Areas Type EBPAQC Located Number Plan with Engagement EBPQAC Year Performed Member Opinion member In Audited Findings 2011 Limited- DC Yes 2007 3 Yes First time Pass VA Yes 22 Scope Audit audited 3 Limited- 2011 DC Yes 2006 Yes Yes CA Pass 4 or 23 Scope Audit more times 2012 Full-Scope 4 or HW Yes 2004 Yes Yes 3 Pass FL 24 with Audit more deficienc times ies First time 2 Limited- NY DC Yes 2007 Yes Yes 2012 Pass 25 Scope Audit audited First time 1 Limited- PA DC Yes 2005 Yes Yes 2010 Pass 26 Scope Audit audited 4 or MO 1 Full-Scope Pass DC Yes 2004 Yes Yes 2011 27 Audit more times 189

192 100-749 Plan Stratum # of Year Number State Peer Audit Peer Member Peer State Type of of Times IQPA Plan Review Became Society Areas of the Review Review Audit Review EBPAQC Plan Number Located Type Opinion Engagement EBPQAC Performed with Member Year member In Audited Findings MN Limited- 4 or more HW Yes 8 Yes Yes 2012 Pass 2004 1 Scope Audit times 4 or more 4 Limited- PA DB Yes 2004 Yes Yes 2010 Pass 2 Scope Audit times 4 or more KS 1 Limited- Pass DC Yes No 2011 Yes Yes 3 Response Scope Audit times 190

193 750 + Plan Stratum # of Number State Year Type of Peer Member Audit Peer of State Peer Review Became IQPA Plan Review Areas Times Society Review Audit Review of the Located EBPAQC Type Number Member with Year EBPQAC Plan Opinion Performed Engagement member In Findings Audited 2011 Pass 4 or IN 5 Limited- Yes DB Yes 2004 Yes 1 Scope Audit more times PA 2011 Pass with First Yes 2 Full-Scope No DC Yes 2004 2 Audit deficiencies time audited MN Yes 4 or 2011 No Pass with Limited- 2004 DC Yes 1 3 Scope Audit more deficiency times 191

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