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In addition, this proposed SAS includes a requirement to report findings from procedures performed on specific plan provisions relating to the financial statements.Early in the development process, the task force concluded that the reporting model changes in this proposed SAS would also require performance requirements to effect certain of the proposed new reporting requirements in addition to those currently set forth in the existing AU-C sections.This proposed SAS is specific to audits of financial statements of employee benefit plans (EBPs) subject to the Employee Retirement Income Security Act of 1974 (ERISA), hereinafter referred to as an ERISA plan, and would be codified as AU-C section 703 in AICPA .The proposed SAS includes the form and content of the auditor’s report for an unmodified opinion, a new form of opinion when an ERISA-permitted audit scope limitation exists and reporting requirements on findings from procedures performed on specific plan provisions relating to the financial statements (either included in the auditor’s report on the ERISA plan financial statements or issued as a separate report).The task force also discussed creating a reporting requirement for ERISA plans similar to the report on compliance in a Yellow Book audit.The ASB has supported exploring the development of new requirements in order to support the reporting of findings from procedures performed on specific plan provisions relating to the financial statements but also acknowledged that adopting such requirements will result in the need for implementation guidance and could lead to possible unintended consequences (see specific questions in the Issues for Consideration).The task force considered this information as this proposed SAS was developed.

At the October 2016 ASB meeting, the ASB discussed whether the auditor’s report should include the details of the communications the auditor makes to those charged with governance about significant deficiencies and material weaknesses identified in an audit as part of its broader project on the auditor reporting model, and concluded that this should remain a communication with management and those charged with governance, as required by AU-C section 265, ).EBSA found that 39 percent of the audits had one or more major deficiencies with respect to one or more relevant requirements of generally accepted auditing standards (GAAS).EBSA also found that 17 percent of the auditor’s reports reviewed in their study failed to comply with one or more of ERISA’s reporting and disclosure requirements.The task force was also asked to consider the audit evidence that is obtained from management who provides the auditor with a certification from a bank or similar institution or insurance carrier which is regulated, supervised, and subject to periodic examination by a state or federal agency, provided that the statements or information regarding assets so held are prepared and certified to by a bank or similar institution, or insurance carrier, in accordance with Title 29 U. Code of Federal Regulations (CFR) Part 2520.103-5 and CFR 2520.103-8 (or CFR 2520.103-12).The proposed SAS would require a new form of report specific to an audit of an ERISA plan when management imposes an ERISA-permitted audit scope limitation.

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