Employee Benefit Plan Audit Peer Reviewsmedia.straffordpub.com/products/employee-benefit-plan... ·...

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Employee Benefit Plan Audit Peer Reviews

THURSDAY, DECEMBER 6, 2018, 1:00-2:50 pm Eastern

FOR LIVE PROGRAM ONLY

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mailto:[email protected]

Dec. 6, 2018

Employee Benefit Plan Audit Peer Reviews

Lauren Hayes, Senior Manager

Montgomery Coscia Greilich, Plano, Texas

[email protected]

Susan J. Peirce, CPA, MTax, Principal

Apple Growth Partners, Akron, Ohio

[email protected]



Notice

ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY

THE SPEAKERS’ FIRMS TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY

OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT

MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR

RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN.

You (and your employees, representatives, or agents) may disclose to any and all persons,

without limitation, the tax treatment or tax structure, or both, of any transaction

described in the associated materials we provide to you, including, but not limited to,

any tax opinions, memoranda, or other tax analyses contained in those materials.

The information contained herein is of a general nature and based on authorities that are

subject to change. Applicability of the information to specific situations should be

determined through consultation with your tax adviser.

• EBSA Audit Quality Initiatives

• Reporting Compliance Initiatives

• DOL Resources

• AICPA Response and Resources

Peer Review continues to be impacted by DOL initiatives

EBSA’s audit quality findings Firms auditing > 200 plans

45 firms perform 37% of the audits covering 69% of plan assets

Firms auditing between 100 and 200 plans

59 firms perform 10% of audits covering 11% of plan assets

Firms auditing < 100 plans

5,721 firms audit 53% of audits covering 20% of plan assets

From Marcus Aron presentation – AICPA EBP conference May 2018

6

EBSA activities Cycle of inspections for all firms auditing > 100 plans

Engagement reviews of smaller firm practices

From Marcus Aron presentation – AICPA EBP conference May 2018

7

EBSA’s findings Overall error rate of 40% isn’t the complete picture

Large variability – size of EBP practice is a factor

Large firms are not immune from problems

They also dabble

Their size creates different risks and problems

Peer review is not a good indicator of a quality benefit plan auditor

From Marcus Aron presentation – AICPA EBP Conference May 2018

8

Other Meaningful Quality Factors based on the EBSA findings

Peer Review is not a useful identifier of quality work In 4 of 6 strata, audits with 5+ GAAS deficiencies

were performed by firms with clean peer review reports.

9

EBSA’s list of best practices Commitment to EBP work from top down

An EBP audit pedigree as well as audit pedigree within the firm

EBP specific training and affiliation

Educate and empower staff

EBP specialists

Robust internal inspection program

Knowing who you are and when to say “no”

Stress consistency throughout EBP practice

10

AICPA Peer Review Response After the 2014 DOL report was released, AICPA

analyzed results of 109 Enhanced Oversight reviews of EBPs

Determined that the DOL audit quality study was similar to the enhanced oversight findings

Identified common areas of non-conformity

Detected misconceptions driving non-conformity

11

Enhanced oversight of EBPs 2015-2016

50%

31%

19%

Conforming engagements

Non-conforming engagements notidentified by reviewers

Non-conforming engagementsidentified by reviewers

12

AICPA enhanced oversight objectives

Objectives

Focus on must-select engagements

Identify material departures from

professional standards

Evaluate the performance of peer

reviewers

Provide education and feedback to peer

reviewers and firms

13

AICPA EBPAQC Resources

EAlerts

Webinars

Website

Member-to-member ForumResource

Centers

Tools

Primers

Plan Advisories

14

AICPA EBPAQC Planning Tool

15

Shared with

permission of

EBPAQC

AICPA response – Competency certificates Early April 2016, the AICPA launched an employee benefit plan

certificate program to allow practitioners to show their competency.

17

18

AICPA response – Competency certificates

AICPA response – Competency framework Creation of competency framework for employee benefit plans will

help practitioners assess whether they have the competency needed for employee benefit plan financial audits and, if not, what curriculum they need to gain competency.

19

Peer Review is Evolving Each Year

21

Enhanced Oversight “ A sound audit does not occur by chance.” Susan S. Coffey,

CPA, AICPA executive vice president

“When the enhanced oversight program first started, the focus was on detecting quality challenges, but the primary focus has evolved to determining the characteristics of the firms we find are performing well, as well as digging deeper to discover why firms with performance issues are not performing well.” Jim

Brackens, CPA AICPA vice president of ethics and practice quality.

22

Specific focus on reforms to enhance quality and accountability

2014 piloted an enhanced oversight program in which subject-matter experts conducted surprise examinations of a sample of engagements after the completion of peer review

2015 program was expanded

2016 pilot program was converted to a permanent part of the Peer Review Program and root cause analysis was introduced

23

Increased focus 2015 and 2016 peer reviews included increased focus

on specialized industries Includes employee benefit plans

Specialized industries

Areas where peer reviewers and expert noted the greatest issues

2017 peer reviews had greater expertise oversight and subject matter expert reviewers performed enhanced assessment of firms’ quality control systems

24

2018 – A Significant Difference

October 2018 Peer Review Alert included clarifications of the September 2018 Peer Alert dealing with Risk Assessment

Critical to read and review your firm’s policies

New Guidance on the Evaluation of Non-compliance with Risk Assessment Standards and its Impact to the Peer Review (PRPM Section 3100, Supplemental Guidance)

25

Use of PPC checklists

Peer Review Board expressed concern with the proper assessment of risk and linking that assessment to audit procedures.

Special Report was issued in September 2018

26

PPC Accounting & Auditing Update Sept 2018:

Quality trends based on the Enhanced Oversight

Analysis indicates the most common cause of material non-conformity in audits is a lack of adequate audit documentation

Inadequate documentation is cause of >50% of non-conformity

2019 peer reviews will have increased emphasis on audit documentation with focus on risk assessment

27

Reporting Requirements

GAAP financial statements are required

Additional regulatory requirements

DOL reporting requirements

IRS reporting requirements

Peer reviews require adherence to ALL of the above requirements

28

Reporting Guidance Related to Peer Review

AICPA Revised Interpretation 63-1Consideration for selection:

A. Reasonable cross-section of the reviewed firm’s accounting and auditing practice

B. Emphasis on higher-risk practice areas

1. Risk of engagements and types of benefit plans as part of the selection criteria

2. Limited vs. full scope

3. Types of plans (DC, DB, H&W and 403(b) plans)

C. Firm’s length of experience and number of audits performed, member’s experience and CPE/specialized training

29

Understanding the Unique Reporting Requirements of Employee Benefit Plans

Users of financial statements

Participants

Plan Sponsor

DOL

IRS

State Insurance Departments

30

Unique risks associated with different types of ERISA plans

Defined contribution – Participant account and allocation testing and timely remittance of participant contributions.

Defined benefit – Actuarial present value of accumulated plan benefits and changes in actuarial present value of accumulated plan benefits.

Health & welfare – Benefit obligations and changes in benefit obligations.

Employee stock ownership plans – Annual appraisal of securities and leveraged ESOPs

Peer reviewer must consider the unique risks and document how these risks were addressed.

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What is the Peer Review Requirement

Licensed firms are required to have peer review

Report acceptance body is either: State peer review committee

AICPA Peer Review Board’s National Peer Review

SEC registrant’s plans are not subject to peer review

Engagements subject to GAAS, SSARA,SSAE, GAGAS and non-SEC issuers are subject to peer review

32

Impact of not enrolling or omission Firms that are not enrolled in the program as required

by AICPA membership bylaws or their state regulatory authority will be referred to AICPA Professional Ethics Division or the appropriate regulatory or licensing authority.

Firms that omit an EBP audit from the scope of their peer review will be notified that their most recent peer review acceptance letter will be recalled.

The firm will be subjected to a hearing panel

33

Peer Review deadline

Peer review is due every 3rd year, six months after the firm’s fiscal year end

This impacts plans that are reviewed

34

Preparing for a Peer Review

Every audit must meet your firm’s QC standards

Be prepared Track general data on the number, size and type of

employee benefit plan audits Peer reviewers must select engagements that are considered to

have added “risk”

full-scope audits

403(b)

ESOPs

Health and welfare

initial engagements

35

Preparing for a Peer Review (cont.)

Interviews with Firm Personnel

EBP team members need to use EBP “language” Training should start with the 1st plan audit

EBP team members need more than checklist mentality

EBP team needs specialized training

Make certain that you are in compliance with your own firm policies

Review results of prior peer review

Workpaper lockdown

Internal inspection

Use AICPA checklist for inspection36

Preparing for a Peer Review (cont.)Peer Review Checklists AICPA Peer Review Program Manual PRP §20,700

(dated September 2018)

37

Employee Benefit Plan Audit Engagement Checklist:


38

2018 Employee Benefit Plans Must-Select FAQs:

Preparing for a Peer Review (cont.)https://www.aicpa.org/content/aicpa/eaq/aicpa-risk-assessment-resources.html

39

https://www.aicpa.org/content/aicpa/eaq/aicpa-risk-assessment-resources.html


Preparation for your next peer review starts as soon as the current review is completed

Correct findings immediately; avoid repeat findings

Communicate findings to your team

Consider using outside professionals to perform internal inspections

Specialized ERISA training for your team

If the outcome is poor, hire a consultant to do a more in-depth review of your ERISA practice and engagements

40

Peer Review Overview

41

Revisiting professional

standards

Anticipating peer reviewer expectations

Best practices & avoiding common auditor

documentation pitfalls

Overview of inspection

requirements & considerations

for EBPAQC members

Revisiting the Professional Standards

42

AU-C Section 230, Audit

Documentation

• Audit documentation required to contain evidence of the following:

• Auditor’s basis for conclusions about achievement of overall objectives of the auditor

• Audit was planned and performed in accordance with GAAS, and applicable legal & regulatory requirements


43


Documentation

• Several purposes served by audit documentation

• For engagement team:

• Assist in planning & performing the audit

• Demonstrate accountability for work performed, evidence examined & conclusions reached

• Retain record of matters of continuing significance to future audits of same entity


44


Documentation

• Necessary for execution of various inspections and reviews

• Quality control reviews & inspections in accordance with QC Section 10, A Firm’s System of Quality Control (SQCS No. 8)

• External inspections or peer reviews in accordance with applicable legal, regulatory or other requirements

• Subsequent year audit team members & predecessor auditor reviews


45


Documentation

• Form, Content & Extent

• Experienced auditor, with no prior connection to the audit, should be able to understand:

• Nature, timing & extent of procedures performed

• Results of audit procedures performed & evidence obtained

• Significant findings & issues

• Conclusions reached

• Significant judgments made in reaching those conclusions


46


Documentation

• A closer look at supporting nature, timing & extent of procedures performed to identify:

• Characteristics of specific items or matters tested

• Abstracts or copies of significant contracts or agreements inspected

• Who performed the work and date completed

• Who reviewed the work performed, date and extent of such review


47


Documentation

• Document justification for any departures from presumptively mandatory requirements

• Support sufficiency of alternative procedures performed

• Document circumstances encountered that led to additional procedures after audit report date

• Procedures, evidence & conclusions

• Resulting changes – by whom & date prepared and reviewed


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Documentation

• Final audit file

• Document audit report release date

• Assemble final documentation & complete administrative process of assembling final audit file on timely basis (“documentation completion date”)

• No later than 60 days following audit report release date

Anticipating Peer Review Audit Documentation ExpectationsWritten Audit Programs and avoiding “One Size Fits All” Mentality

49

• Defined benefit or defined contribution pension

• Health and welfare benefit plansType of Plan

• Full scope

• Special considerations for plans subject to SEC filing

• Limited scope audit exemption

Engagement Scope

Anticipating Peer Review Audit Documentation Expectations

50

• Engagement quality control reviews

• Internal inspection program

• CPE and related compliance

• Independence (AICPA, DOL, SEC/PCAOB, etc.)

• Client acceptance & re-acceptance

Ensure Engagement

Quality Complies with Professional Standards

Firm’s System of Quality Controls in Accordance with Statement on Quality Control Standard No. 8

Anticipating Peer Review Audit Documentation Expectations

51

Firm’s System of Quality Controls in Accordance with Statement on Quality Control Standard No. 8

• Inspection results

• Maintenance of CPE compliance tracking mechanisms

• Policy for & results of review of certain documents by individual outside of engagement team

Measurement of Compliance

with Professional Standards

Presenter’s Bio Susan J. Peirce, CPA, MTax

Sue Peirce is a principal and leads the employee benefits audit and specialty services team at Apple Growth Partners. Sue has led the development of numerous services at the firm including specialty audit services, benefit plan design and administration, and SOC engagements. She has implemented Lean principles in the delivery of audit services to achieve more efficient processes and outcomes in audit engagements. Sue regularly writes articles, hosts webinars, and has presented at numerous events including the AICPA National Employee Benefit Plan Conference, Matrix Financial Solutions Annual Conference, and various state CPA societies.

In addition to her audit work, she provides consulting services to business owners and professionals with a special emphasis on benefit plan services. Her expertise includes a focus on qualified retirement plans and related design, compliance, non-discrimination testing, distribution and reporting issues.

Sue is a former member of the AICPA Employee Benefit Plan Audit Quality Center Executive Committee.

52

© 2018 Montgomery Coscia Greilich LLP 53

Common Plan Audit Deficiencies

EBPAQC Membership

Peer Review Process/Best Practice


COMMON PLAN AUDIT

DEFICIENCIES


ESOPs: Over 50% of plans subject to DOL inspection contained deficiencies• Failure to identify valuation of employer stock in the risk assessment

• Review of the work of the appraiser (full-scope audits)

• Testing releases of shares and purchases of shares

H&W Plans• Can be extremely complicated with various benefits included under the

plan

• Audit of the trust versus the plan

Multi-Employer Plans

High Risk Engagements


Most Common Audit Issues

• SOC analysis deficiencies

• Investment testing deficiencies

• Participant data testing deficiencies

• Documentation issues

• Non attest services


Service Auditor Reports

• Was a type 1 or type 2 SOC 1 report used as audit evidence to support the Firm’s understanding about the design and implementation of controls?

• If a type 2 is reducing procedures, was it properly evaluated?

• EBPAQC has a tool for documenting consideration of SOC reports


Risk Assessment

Recent AICPA Requirements:• Peer reviewers have been instructed to identify an engagement as “not

performed” in accordance with professional standards if the peer reviewer identifies non-compliance with the Risk Assessment Standards covered in AU-C sections 315 and 330

• Risk assessment documentation findings should be included in the oversight report as findings that result in a non-conforming engagement

• Effective for peer reviews commencing on or after October 1, 2018


Failure to gain an understanding of internal control when identifying client’s risks:

Auditors are expected to perform the following steps when gaining an understanding of internal control; an audit omitting one or more of these steps results in non-compliance

• Consider what could go wrong as the client prepares its financial statements

• Identify the controls intended to mitigate those financial reporting risks

• Evaluate the likelihood that the controls are capable of effectively preventing or detecting and correcting material misstatements.

Some auditors may indicate that the requirements of AU-C 315.14 do not apply to their client because their client has no controls. This is a false assumption.

Auditors may default to control risk at the maximum level without gaining an understanding of the client’s internal control. This is not permitted under the current Risk Assessment Standards, even when not intending to rely on tests of controls.

Auditors may reduce control risk to less than high without appropriately testing relevant controls.

Risk Assessment


Insufficient risk assessment:

Regardless of the nature and extent of substantive procedures, performing the audit in accordance with GAAS includes the following requirements for each engagement; omitting one or more of these requirements results in non-compliance

• Identify the client’s risks of material misstatement (RMM) by gaining an understanding of the client and its internal control (Identify RMM)

• Assess the risks (Assess RMM) and

• Design or select procedures that respond to those risks (Respond to RMM)

Failure to identify at least one significant risk almost always represents a failure to comply with AU-C 315.28

Failure to assess risk of material misstatement at both the financial statement level and relevant assertion-level for significant classes of transactions, account balances or disclosures represents non-compliance with AU-C 315.26

Some auditors are documenting RMM at the audit area level for every audit area, citing the risk assessment is the same for all assertions, when not all assertions are relevant

Risk Assessment


Failure to link procedures performed to the risk assessment:

Audit procedures should be responsive to the client’s financial statement-and relevant assertion-level risks for significant classes of transactions, account balances or disclosures. The linkage is at the assertion (not account) level.

Some auditors are performing the risk assessment in accordance with AU-C 315 but designing the audit procedures with little regard for the results of that assessment. If the risks are not properly reduced to an acceptably low level, the auditor hasn’t complied with the standards.

Risk Assessment


Participant Data/Accounts:

Audit Objective

To provide the auditor with a reasonable basis for concluding (a) whether all covered employees have been properly included in employee eligibility records and, if applicable, in contribution reports; and (b) whether accurate participant data for eligible employees were supplied to the plan administrator and, if appropriate, to the plan actuary


• No audit work performed or no audit documentation of testing participant data

• Testing of payroll data insufficient

✓ Risk of plan non-compliance with provisions – definition of eligible compensation (also effects contributions)

• No testing of participant eligibility, termination or forfeitures

✓ Risk of plan non-compliance with provisions – missed or late entry dates, entry date too early

✓ Forfeitures miscalculated, forfeitures not used in accordance with the plan

• No testing of investment income or investment election allocation to participants

• No reconciliation of participant accounts to total plan assets

Participant Data/Accounts:

Audit Objective


Full scope audit – To provide the auditor with a reasonable basis for concluding

a) whether all investments are recorded and exist;

b) whether investments are owned by the plan and are free of liens, pledges, and other security interest or, if not, whether the security interests are identified;

c) whether investment principal and income transactions are recorded and investments are properly valued in conformity with U.S. generally accepted accounting principles as promulgated by the Financial Accounting Standards Board (FASB) (GAAP) or a special purpose framework that is acceptable to the DOL, such as the modified cash basis of accounting;

d) whether information about investments is properly presented and disclosed; and

e) whether investment transactions are initiated in accordance with the established investment policies

Investments:

Audit Objective


Limited scope audit - The auditor’s responsibilities for any assets covered by the limited scope exception are

a) to compare the information certified by the plan’s trustees or custodian to the financial information contained in the plan’s financial statements;

b) to perform the necessary procedures to become satisfied that any received or disbursed amounts reported by the trustee or custodian were determined in accordance with the plan provisions; and

c) whether information about investments is properly presented and disclosed.

Investments:

Audit Objective


Full scope audits:• Failure to test investment transactions and/or income

• Failure to test end-of-year market values

• Failure to confirm existence and ownership of investments through direct confirmation procedures

Limited scope audits:• Failure to obtain proper certification

• Improper use of limited scope exemptions

• Failure to understand testing requirements

Inadequate or missing disclosures related to investments

Investments:

Audit Objective


To provide the auditor with a reasonable basis for concluding (a) whether the amounts received or due the plan have been determined and recorded and disclosed in the financial statements in conformity with plan documents and generally accepted accounting principles; and (b) whether an appropriate allowance has been made for uncollectible plan contributions receivable in conformity with GAAP or a special purpose framework

Contributions:

Audit Objective


• No audit work performed or no audit documentation

• Insufficient testing on contributing employers for multi-employer plans

• Failure to test compliance with compensation provisions

✓ This is the area that most non-compliance is found in a plan - Improper definition of eligible compensation

• Failure to test forfeitures

• Timeliness of participant contributions not tested

Contributions:

Common Deficiencies


Provide the auditor with a reasonable basis for concluding (a) whether the payments are in accordance with plan provisions and related documents; (b) whether the payments are made to or on behalf of persons entitled to them and only to such persons; and (c) whether transactions are recorded in the proper account, amount and period

Benefit Payments:

Audit Objective


• No audit documentation or no audit work performed

• Failure to test participant eligibility to receive benefit payments

• Failure to test approval/validity of benefit payments

• Failure to test vesting

Benefit Payments:

Audit Objective


• Lack of documentation results in a majority of peer reviewer findings

• Firms are required to document:

✓ Nature, timing, and extent of procedures

✓ Results of those procedures

✓ Any significant findings, issues, or professional judgement

• Remember…if you didn’t document the procedure, it’s considered not to have been done

Documentation:

Common Deficiencies


• No audit documentation or no audit work performed for related-party and party-in-interest transactions

• Failure to understand and/or test administrative expenses

• Inadequate planning and supervision

• Non-attest services not documented

• Reporting:

✓ Incomplete description of the plan and its provisions

✓ Failure to properly report on and/or include the required supplemental schedules relating to ERISA and DOL

Other Areas:

Common Deficiencies


Materiality

Plan Financial Statement

Level

Regulatory / Participant

Level


EBPAQCMEMBERSHIP


• Designated audit partner in charge of EBP

• Partners must be members of AICPA

• System of quality control

• Monitoring program with internal inspections

• Peer review report made public

• EBPs must be selected for peer review

• Periodically file information about EBP practice

• Pay dues established by executive committee

EBPAQC Membership Requirements

Considerations for EBPAQC Members


• Review of specific engagements

• Review of CPE records

• Review of training program (if applicable)

• Summarize and evaluate the findings

• Communicate inspection results

• Remediate issues as needed

• See AICPA EBPAQC tool on Web site

Inspection Program Requirements for

Internal and External Peer Reviews

Considerations for EBPAQC Members


PEER REVIEW

PROCESS


Peer reviewers look at the firm as a whole and perform “risk assessment.”• Understand the firm

• Commitment to the employee benefit plan practice

• Understand where the EBP practice fits in the overall firm’s practice

• Approach to maintaining quality to employee benefit plans

Peer Review Process


• Gain an understanding of the firm and assesses risk

• Select engagements

• Review engagements - AICPA EBP audit engagement checklist

✓ Report and related disclosures

✓ General audit procedures

✓Working paper areas

• Engagement team responds and clarifies any “No” answers.

Peer Review Process


Matters

• Most minor issues related to documentation, and no material misstatement

• Communicated on matters for further consideration (“MFC”)

• Still a good audit with “pass” rating

Findings

• One or more matters that suggest quality control issues

• Documented on a findings for further consideration (“FFC”) form

• If conclusion is not a deficiency or significant deficiency, = a “pass” rating

Deficiencies

• One or more findings that were material and/or not in conformity with the applicable professional standards requirements

• Rating “pass with deficiencies” report

Significant deficiencies

• Consistent findings of deficiencies

• Inadequate or insufficient procedures performed

• Material departures from applicable standards

• Rating “fail” report

Types of Observations Types of Findings

Peer Review Process


Finalize and submit the report• Read, review, and respond to MFC and FFC carefully

• Understand the requirements imposed by the standards

• Final product of a peer review is the report sent to governing bodies.

When you disagree with findings prior to issuance• Consult with the AICPA technical review committee

• State society

Peer Review Process


PEER REVIEW

BEST PRACTICES


Best Practices for Preparing

for a Peer Review

Establish organizational structure for employee benefit plans• Firm practice leader/technical resource

• Identify the engagement teams working on employee benefit plan audits

• Continuity in engagement teams

Practice makes perfect - annual internal inspections• Structure the internal reviews using AICPA checklists

• Require engagement teams to respond to findings

• Communicate the findings and remediate


Use your client management system to separately track employee benefit plan audits• Track general data on the number, size, and type of employee benefit

plan audits

Pay extra attention to the riskier types of engagements


for a Peer Review


Ensure the documentation is complete and accurate• Compliance with documentation standards; AU-C section 230, Audit

Documentation

• Special emphasis on documentation of consultations and use of specialists

• Include memos to document approach

Maintain CPE records • Ensure EBP specific CPE is being provided

• Monitor EBP CPE requirement


for a Peer Review


Coordinate the timing and offices to be visited by the peer review team, and ensure to communicate to your local offices

Identify and prepare those who will be involved in the peer review process• Peer reviewers generally interview members of management, quality

control and staff.

• Educate teams involved in peer review with process and rating scale

Learn from past experience• Address previous peer review comments with engagement teams

• Address quality control issues

• Consider specialized training for your teams


for a Peer Review


Lauren Hayes, CPA, CIA

Lauren Hayes is a Senior Audit Manager with Montgomery CosciaGreilich, LLP, the largest locally-owned accounting firm based in theDallas/Fort Worth area. Lauren specializes in audits of employeebenefit plans and investment companies.

Lauren has extensive experience with employee benefit plans includingdefined contribution plans, defined benefit plans, health and welfareplans, cash balance plans, and employee stock ownership plans forboth public and non-public companies. Through this practice, Laurenhas aided clients with complex investment reporting and valuations,plan document compliance reviews, and related plan documentcompliance corrections.

Phone: 972-748-0351

Email: [email protected]

2500 Dallas Parkway, Suite 300

Plano, Texas 75093

300 Throckmorton Street, Suite 520

Fort Worth, Texas 76102

2901 Via Fortuna, Building 6, Suite 550

Austin, Texas 78746

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