Yes! You can use AI to fill out Fidelity NetBenefits Auditor's Guide: An Overview of Fidelity's 2024 Plan Year Reporting Package
The Fidelity NetBenefits Auditor's Guide is an annual reference document published by Fidelity Workplace Services for independent auditors and plan sponsors whose retirement plans require an audit as part of the Form 5500 reporting process. It covers key topics including plan year-end summary reports, SOC 1 attestation standards, participant loan auditing, benefit payment testing, forfeiture account review, specialty fund features, and Form 5500 filing requirements. The guide is designed to streamline the audit process by explaining how to access reports through Fidelity's Plan Sponsor WebStation (PSW®), interpret financial data, and reconcile plan activity. Today, related forms and supporting documentation referenced in this guide can be prepared quickly and accurately using AI-powered services like Instafill.ai, which can also convert non-fillable PDF versions of audit-related forms into interactive fillable formats.
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Form specifications
| Form name: | Fidelity NetBenefits Auditor's Guide: An Overview of Fidelity's 2024 Plan Year Reporting Package |
| Number of pages: | 1 |
| Filled form examples: | Form Fidelity Auditor's Guide 2024 Examples |
| Language: | English |
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Follow these steps to fill out your FIDELITY AUDITOR'S GUIDE 2024 form online using Instafill.ai:
- 1 Navigate to Instafill.ai and upload or select the relevant audit support form or document referenced in the Fidelity Auditor's Guide, such as the Sample Request Form or PSW® User Access Form.
- 2 Review the form fields and use Instafill.ai's AI-powered suggestions to identify the required participant, plan, and transaction information needed to complete the form accurately.
- 3 Enter plan-specific details such as the plan number, plan year end date, participant SSNs, transaction types, and applicable summary rule codes as referenced in the Fidelity Plan Year End Summary Reports.
- 4 Attach any supporting documentation required, such as check copy requests, loan paperwork selections, or rollover documentation, following the guidance outlined in the Auditor's Guide sections on sampling and documentation requests.
- 5 Review all entered information for accuracy against Fidelity's PSW® reports (e.g., Balance Info Summary Extract, Withdrawals Report, Annual Loan Balance Report) to ensure consistency before submission.
- 6 Use Instafill.ai to finalize and export the completed form, then submit it via a PSW® Audit Support Service Request or provide it to the plan sponsor for submission to Fidelity's Audit Support Team.
- 7 Retain a copy of the completed form and any response documentation received from Fidelity for inclusion in the audit workpapers and Form 5500 filing support.
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Frequently Asked Questions About Form Fidelity Auditor's Guide 2024
The Auditor's Guide is a resource provided by Fidelity to support independent auditors performing plan audits related to the Form 5500 reporting process. It provides relevant information, report descriptions, and guidance for auditing defined contribution plans recordkept by Fidelity, including how to access reports, request documentation, and reconcile plan financials.
This guide should be forwarded to your independent auditor if your company is a Fidelity Institutional client and your plan is required to have an audit as part of the Form 5500 reporting process. It is designed for use by both plan sponsors and their independent auditors.
To receive access to PSW®, the plan sponsor must complete the Fidelity PSW® User Access Form, which includes a specific access option for auditors. The form can be found in PSW® under 'Administer Plans' > 'Plan Year End Summary Reports' > 'General Audit Documents' tab. Once completed and signed by an authorized individual, it should be submitted via a PSW® General Service Request by the plan sponsor.
Plan Year End Summary Reports can be accessed in PSW® by navigating to the hamburger menu, selecting 'Administer Plans,' and then choosing 'Plan Year End Summary Reports.' The page contains three tabs: 'Plan Financials' (standard reports like Trial Balance, SOPO, and 5500 Worksheet), 'Requested Reports' (custom reports), and 'General Audit Documents' (non-plan-specific resources like the Auditor's Guide and SOC 1 Reports). Reports for up to the previous seven plan years are available.
Auditors submit requests using the Sample Request Form, which is found in the 'General Audit Documents' tab on the Plan Year End Summary Reports page in PSW®. The completed form is submitted via a PSW® Audit Support Service Request. Check copies are only available for transactions with a payment method of 'Check – Deutsche,' 'Check – Wells Fargo,' 'Check – JP Morgan Chase,' or 'Check – Citibank.' Paperwork is available for categories such as Hardship Withdrawal, Loan, QDRO, Rollover In, Rollover Out, and Withdrawal.
The FMTC (Fidelity Management Trust Company) Certification Letter is issued when FMTC served as trustee of a qualified retirement plan or custodian for a 403(b) plan. It verifies the accuracy and completeness of the Plan Year End Summary Reports, including the Summary of Net Trust Assets, Summary of Plan Operations, 5500 Worksheet, BrokerageLink Asset Detail Report, and Year End Trial Balance. It also covers participant loans and self-directed brokerage (BrokerageLink) accounts.
Fidelity provides several SOC 1 reports: the FWS LLC DC Recordkeeping SOC 1 (covering 401(k) and 403(b) plans), the FTG (Fidelity Technology Group) SOC 1, the FFIO SOC 1 (for plans with non-registered investment vehicles), and the NFS SOC 1 (for plans with self-directed brokerage accounts). These reports are available on the PSW® Home page under Quick Links > SOC 1 Reports. Quarterly bridge letters are also issued to cover periods after the annual SOC 1 reporting period (November 1 – October 31).
Both reports are income statements reflecting the plan's financial activity, but they use different cost accounting methods to calculate realized gains and losses. The SOPO calculates gains/losses using revalued cost, while the Trial Balance uses historical cost. The sum of realized and unrealized gains/losses from both reports will be equal. Additionally, the Trial Balance does not include an actual amount for unrealized gains/losses, and neither report should generally be used to complete the income and expense section of Form 5500 — the 5500 Worksheet should be used instead.
Deemed distributions occur when an active participant defaults on a loan and is not eligible for a plan distribution. They are reported on Form 5500 Schedule H or I, Line 2(g) as 'certain deemed distributions of participant loans.' The outstanding loan balance is removed from plan assets on the Summary of Net Trust Assets and 5500 Worksheet, but remains on the SOPO and Trial Balance. If a participant later resumes repayment of a deemed loan, Line 2(g) must be reduced by the original amount previously reported, which can result in a negative value.
Several reports are available to audit the forfeiture account, which is maintained under SSN 999-99-9999F. The Balance Info Summary Extract (BISE) provides a roll-forward of the account. The Audit Forfeiture Activity Report and Audit Forfeiture Debit Credit Report (both available via Enhanced PSW® Reporting) provide detailed transaction information. Additional reports include the Forfeiture Trial Balance and Forfeiture Statement (available via PSW® Service Request), as well as the Outstanding Check Participant Notification Report and Outstanding Checks Forfeiture Posting Summary Report.
SECURE 2.0, signed into law on December 29, 2022, includes provisions such as increasing the required minimum distribution age from 72 to 73, effective January 1, 2023. For auditing purposes, relevant PSW® reports include the Audit Auto Enrollment Report, Audit Summary Rules Report, Audit Withdrawals by Type Report, and Contributions Report. Additional resources and guides on SECURE 2.0 provisions are available on PSW® under 'The SECURE 2.0 ACT of 2022.'
Yes — services like Instafill.ai use AI to auto-fill form fields accurately and can save significant time when completing audit-related forms and documentation. If you are working with PDF forms that are not fillable, Instafill.ai can also convert flat, non-fillable PDFs into interactive fillable forms, making the process more efficient for auditors and plan sponsors alike.
Auditors can contact Fidelity's Audit Support Team through two main channels: (1) PSW® Service Requests, which can be opened from the Plan Year End Summary page under 'Need Help?' or via the 'Working With Fidelity' tab — the plan sponsor must grant the auditor permission to open Service Requests; and (2) the Audit Support Helpline, available Monday through Friday from 8 AM to 6 PM ET for complex inquiries best addressed through live dialogue. Note that Fidelity does not accept audit packages or inquiries via email.
A large plan filer generally has 100 or more participants with account balances at the beginning of the plan year (reported on Form 5500 Line 6g(1)), files Schedule H, and is required to have an audit by an independent qualified public accountant (IQPA). A small plan filer generally has fewer than 100 participants, files Schedule I or Form 5500-SF, and generally does not require an audit. The 80-120 Rule allows plans with participant counts between 80 and 120 to continue filing the same schedule as the prior year.
For stable value funds like the Managed Income Portfolio (MIP), MIP II, and Fidelity Advisor Stable Value Fund, Fidelity provides a Fair Value Certification letter available in the 'Plan Financials' tab of the Plan Year End Summary Reports page. These funds are presented at contract value on the SONTA but must be reported at fair value on Form 5500 Schedules H and I, creating a reconciling footnote. Fidelity provides fund-level fair value data (including investments at fair value, wrapper contracts, and total contract value) to help plans calculate their proportionate share of fair value for reporting and disclosure purposes.
Compliance Fidelity Auditor's Guide 2024
Validation Checks by Instafill.ai
1
Ensures the FMTC Certification Letter Covers All Required Investment Types
This check verifies that the Fidelity Management Trust Company (FMTC) Certification Letter explicitly covers all certified reports in the Plan Year End Summary (PYES) package, including the Summary of Net Trust Assets, Summary of Plan Operations, 5500 Worksheet, BrokerageLink Asset Detail Report, and Year End Trial Balance. The certification must confirm both accuracy and completeness of investment information as required under ERISA Section 103(a)(3)(C) and 29 CFR 2520.103-5. If any certified report is missing from the certification scope, the plan's ERISA Section 103(a)(3)(C) audit election may be invalid, potentially requiring a full-scope audit and triggering DOL compliance issues.
2
Validates Loan Balance Consistency Across SOPO, Trial Balance, and 5500 Worksheet
This check confirms that the outstanding participant loan balances reconcile correctly across the Summary of Plan Operations (SOPO), Year End Trial Balance, Summary of Net Trust Assets (SONTA), and the 5500 Worksheet, accounting for deemed distributions with no post-default payments. The SOPO and Trial Balance include all loan balances (deemed and active), while the SONTA and 5500 Worksheet exclude deemed distributions with no post-default payments since they are no longer considered plan assets. Failure to reconcile these differences will result in incorrect Form 5500 Schedule H or I reporting of participant loan balances and may misstate plan net assets.
3
Verifies Participant SSN Format and Completeness on Sample Request Forms
This check ensures that all Social Security Numbers (SSNs) entered on Sample Request Forms for check copies, loan paperwork, QDRO documentation, and beneficiary transfers are properly formatted as nine-digit numbers and are not blank or placeholder values. The guide notes that ten-digit SSNs are used for beneficiary and alternate payee accounts and require special handling through the Audit Support Team rather than standard PSW reporting. If SSNs are missing, incorrectly formatted, or use the wrong digit count for the account type, Fidelity will be unable to fulfill the documentation request, causing audit delays and incomplete substantive testing.
4
Confirms Forfeiture Account SSN Identifier is Correctly Referenced as 999-99-9999F
This check validates that any references to the plan's forfeiture account in audit reports, the Balance Info Summary Extract (BISE), and service requests use the correct system identifier SSN of 999-99-9999F, and that the account is labeled as 'FORFEITURE ACCOUNT' in the first/last name fields. Plans may have multiple forfeiture accounts with different suffixes (e.g., E, M, O, J), and each must be identified separately. If the forfeiture account is not correctly identified, forfeiture balances may be omitted from audit testing, leading to undetected misstatements in plan assets and potential violations of plan document requirements governing forfeiture usage timing.
5
Validates Check Copy Requests Include Only Eligible Payment Types
This check ensures that check copy requests submitted via the Sample Request Form only reference transactions with payment types of 'Check – Deutsche', 'Check – Wells Fargo', 'Check – JP Morgan Chase', or 'Check – Citibank', as these are the only payment methods for which physical check copies are available. Transactions with payment types of 'Advice', 'Adjustment (ADJM)', or 'EFT – Bank Name' do not have check copies available and should not be included in check copy requests. Submitting requests for ineligible payment types will result in unfulfilled requests, wasted turnaround time, and gaps in audit evidence for benefit payment testing.
6
Ensures Loan Term Does Not Exceed Regulatory Maximums by Loan Type
This check verifies that general purpose loans do not exceed a five-year repayment term and that home loans (for purchase of a primary residence) are the only loan type permitted to exceed five years, consistent with IRC Section 72(p) and IRS Loan Regulation 1.72(p)-1. The check also confirms that loan repayments are substantially equal and made at least every calendar quarter over the life of the loan. If a general purpose loan is found with a term exceeding five years, or if repayment schedules are not substantially equal, the loan may be treated as a deemed distribution, triggering tax consequences for the participant and potential Form 5500 reporting adjustments.
7
Validates Participant Count Line 6 Calculations Are Internally Consistent on Form 5500
This check confirms that the participant count figures reported on Form 5500 Line 6 are mathematically consistent, specifically that Line 6d equals the sum of Lines 6a(2), 6b, and 6c; that Line 6f equals the sum of Lines 6d and 6e; and that Line 6g(2) equals the sum of active participants with balances plus Lines 6b, 6c, and 6e. It also verifies that Line 6g(1) matches the prior year's Line 6g(2) for plans continuously on Fidelity's recordkeeping system. Errors in participant count calculations directly affect whether a plan is classified as a large or small filer, which determines audit requirements, the applicable financial schedule (Schedule H vs. Schedule I), and compliance with ERISA reporting obligations.
8
Confirms Hardship Withdrawal Documentation Type Matches Transaction Sponsor Approval Method
This check verifies that hardship withdrawal documentation requests are directed to the correct party based on the transaction type: sponsor-directed hardships should be requested from Fidelity via the Sample Request Form, sponsor-approved hardships must be obtained from the plan sponsor directly, and e-Certified Safe Harbor hardships require the E-Certified Safe Harbor Hardship Report from Enhanced PSW Reporting rather than physical paperwork. The SUMM RULE column of the Withdrawals Report must show a code beginning with 'HW' to confirm the transaction is a hardship withdrawal. Misidentifying the documentation source will result in unfulfilled requests, incomplete audit evidence, and potential inability to verify that hardship withdrawals met plan requirements and IRS safe harbor criteria.
9
Verifies Deemed Distribution Reporting Correctly Excludes No-Post-Default Loans from Plan Assets
This check ensures that the outstanding loan balance reported on the Summary of Net Trust Assets and 5500 Worksheet is reduced by the total amount of deemed distributions with no post-default payments, as these loans are no longer considered plan assets for Form 5500 reporting purposes. The check also confirms that deemed distributions with post-default payments remain included as plan assets, and that the net deemed distribution expense on Form 5500 Line 2g reflects the current year activity net of any repayments of prior-year deemed loans, which may result in a negative value. Failure to properly exclude no-post-default deemed loans from the asset statement will overstate plan assets on Schedule H or I and misrepresent the plan's financial position.
10
Validates Stable Value Fund Fair Value Calculation Uses Correct Plan Book Value Percentage
This check confirms that the calculation of a plan's fair value for stable value pooled funds (Managed Income Portfolio, MIP II, and Fidelity Advisor Stable Value Fund) correctly uses the plan's book value as a percentage of the total fund investments at contract value, then applies that percentage to the fund's net assets at fair value, and separately calculates the wrapper rebid value adjustment. The resulting fair value must be used to adjust the Net Investment Gain/Loss from Common/Collective Trusts on the 5500 Worksheet, not the contract value from the SOPO. If the fair value calculation uses incorrect inputs or omits the wrapper contract adjustment, the plan's investment income and net assets will be misstated on Form 5500 Schedule H and in the audited financial statements.
11
Ensures Beneficiary Transfer and QDRO Sample Request Forms Include Both Participant and Alternate Payee SSNs
This check verifies that Sample Request Forms submitted for beneficiary transfers and Qualified Domestic Relations Order (QDRO) documentation include complete information for both the original participant (SSN, full name) and the beneficiary or alternate payee (full name and SSN), along with the correct transaction date, net check amount, and transaction code (e.g., 'Beneficiary Transfer' or 'QDRO Transfer'). The transfer-to and transfer-from amounts must net to zero and share the same trade date. Incomplete forms will be returned by Fidelity, delaying the audit, and missing alternate payee SSNs may prevent proper identification of the transaction in the Transfer Report, leaving QDRO and beneficiary transactions untested.
12
Confirms Exchange-In and Exchange-Out Amounts Net to Zero Except for Real-Time Traded Stock Settlement Differences
This check validates that exchange-in and exchange-out transactions on the Summary of Plan Operations and Year End Trial Balance net to zero at the plan level, with the only permitted exception being real-time traded stock, which as of May 28, 2024 has a T+1 settlement period for exchanges out of the stock fund. Any non-zero net exchange amount not attributable to real-time traded stock settlement timing should be investigated using the Audit Participant Level Activity Report filtered to transaction types '12-Exchange Out' and '5-Exchange In' for the last day of the plan year. Unresolved exchange imbalances may indicate recording errors, unauthorized fund movements, or system reconciliation failures that could misstate plan assets and income.
13
Validates Schedule C Reporting Threshold and Service Provider EIN Completeness
This check ensures that all service providers who received $5,000 or more in total compensation (direct or indirect) in connection with plan services are identified on the Schedule C Supplemental Report, and that each entry includes the provider's full legal name, EIN as it appears on their W-9, applicable DOL service code, and relationship to the employer. Entries showing '99-9999999' or 'SEE NOTE *2' in the EIN field indicate missing data that must be resolved using plan records before filing. Incomplete Schedule C reporting constitutes a Form 5500 filing deficiency that may trigger DOL inquiries, and failure to report eligible indirect compensation under the alternative reporting option requires full disclosure of indirect compensation amounts and formulas.
14
Verifies Forfeiture Account Usage Complies with Plan Document Timing Requirements
This check confirms that forfeiture balances are being used within the plan year in which they are incurred, or no later than the following plan year as permitted by the plan document, and that the specific use (offsetting employer contributions, paying plan expenses, or reallocating to eligible participants) is authorized by the plan document. The Audit Forfeiture Activity Report should be reviewed to identify transaction codes 219-CONTRIB ADJ for contribution corrections, 575-ADMINISTRATIVE FEES and 579-OTHER RECORDKEEPING FEE for expense payments, and 436-10 transfers for uncashed check activity. Failure to exhaust forfeitures within the required timeframe or using them for unauthorized purposes constitutes a plan operational failure that may require correction under IRS Employee Plans Compliance Resolution System (EPCRS).
15
Confirms PSW Auditor Access Authorization is Properly Documented and Current
This check verifies that any third-party auditor accessing PSW has been granted access through a completed and signed PSW User Access Form submitted by an authorized plan sponsor representative, and that the auditor's access level is appropriate for the audit tasks being performed (e.g., Service Request access, Form 5500 access, NDT page access). The guide notes that Fidelity's Audit Support Team cannot update PSW access requests, and that access must be recertified by the plan sponsor every six months per the Illustrative Complementary User Entity Controls. If auditor access is not properly authorized or has expired, the auditor may be unable to retrieve required reports, open service requests, or access Form 5500 data, causing significant delays in the audit engagement.
16
Validates SDB Market Value Reconciliation Between Summary of Net Trust Assets and Summary of Plan Operations
This check confirms that the difference between the Self-Directed Brokerage (SDB) total market value on the Summary of Net Trust Assets and the end-of-year market value on the Summary of Plan Operations is fully explained by the SDB Recon folder items, specifically the Net Adjustment to Income from the Transfer Worksheet plus the prior year market value difference minus the current year market value difference from the Overview Worksheet. The adjustment amount on the SOPO or Trial Balance must also reconcile to the Total Income on page 2 of the SDB 5500 Worksheet in the BrokerageLink Asset Detail Report. Unreconciled SDB differences indicate that the FPRS and FBSI systems are out of sync, which would misstate plan assets and investment income on the Form 5500 and audited financial statements.
Common Mistakes in Completing Fidelity Auditor's Guide 2024
Auditors or plan sponsors often attempt to email Fidelity directly or call the wrong team to set up PSW® access, not realizing that access must be granted through a formal PSW® User Access Form submitted via a General Service Request by an authorized plan sponsor representative. This causes delays in the audit process and can result in the auditor being unable to access critical reports. To avoid this, the plan sponsor must complete the PSW® Auditor Access Form found under 'Administer Plans' > 'Plan Year End Summary Reports' > 'General Audit Documents' tab, have it signed by an authorized individual, and submit it via a PSW® General Service Request. Note that Fidelity's Audit Support Team cannot process access requests.
A common mistake is using the Summary of Plan Operations (SOPO) as the basis for completing the income and expense sections of Form 5500, when the 5500 Worksheet is the correct document for this purpose. The SOPO may reflect deemed distributions that distort income and expense figures, making it unsuitable for direct Form 5500 preparation. Auditors and plan sponsors should always use the 5500 Worksheet for Form 5500 income and expense reporting, and refer to Section 4 of the Auditor's Guide for detailed report mapping between the PYES reports and the Form 5500 schedules.
Auditors frequently submit Sample Request Forms with missing fields—such as the participant's full SSN, full name, net check amount, check number, or payment type—which causes the request to be returned and significantly delays the audit. The form requires all fields to be completed, and an error message will indicate missing information. To avoid this, auditors should reference the R25 Check Register Report and/or the Withdrawals Report to gather all required data before completing the form, and remember that check copies are only available for transactions with a payment method of 'Check – Deutsche,' 'Check – Wells Fargo,' 'Check – JP Morgan Chase,' or 'Check – Citibank.'
Auditors often fail to distinguish between 'Deemed with Post Default Payments' and 'Deemed with No Post Default Payments' loan columns in the Summary of Total Loan Activity (SOTLA), leading to incorrect loan balance reconciliations and Form 5500 reporting. Loans in the 'Deemed with No Post Default Payments' column are no longer considered plan assets and must be excluded from the Summary of Net Trust Assets and the 5500 Worksheet, creating an intentional difference from the SOPO totals. Auditors should carefully review Section 5 of the Auditor's Guide and the Default Loan Details Report to understand each loan category and ensure only reportable loan balances are included on Form 5500.
Auditors frequently flag a discrepancy between the realized gains/losses on the Trial Balance and those on the Summary of Plan Operations (SOPO) as a potential error, when in fact this difference is by design. The Trial Balance calculates gains/losses using historical cost on a moving-average basis, while the SOPO uses revalued cost as required by Form 5500 instructions. The sum of realized and unrealized gains/losses from both reports will equal each other in total. Auditors should refer to Illustration 6.1.27 in the Auditor's Guide for a reconciliation example and avoid treating this difference as a discrepancy requiring correction.
Plan sponsors and auditors sometimes attach PDF documents that are encrypted or password-protected to restrict editing, printing, or viewing when filing Form 5500 through EFAST2. The DOL's EFAST2 system will automatically remove such attachments from the filing, potentially resulting in an error indicating a missing attachment and an incomplete or rejected filing. To avoid this, any PDF attachments must not have restrictions on editing, printing, or viewing. If security is a concern, the PDF should instead be signed or certified with a digital ID, which is acceptable for EFAST2 submission.
Auditors and plan sponsors often misclassify investment types when mapping plan assets from the Summary of Net Trust Assets to the 5500 Worksheet, particularly for Common/Collective Trusts, Stable Value funds, Unitized Stock funds, and Self-Directed Brokerage accounts. For example, Money Market funds with a stable NAV map to 'Interest-bearing Cash' [1(c)(1)], while those with a floating NAV map to 'Interest in Registered Investment Companies' [1(c)(13)]. Auditors should use the fund code on the Trial Balance and the asset classification table in Section 4.1 of the Auditor's Guide to correctly identify and map each investment type to the appropriate Form 5500 Schedule H or Schedule I line.
Auditors frequently submit paperwork requests to Fidelity for sponsor-approved or pre-approved transactions, not realizing that Fidelity does not maintain documentation for these transaction types. For sponsor-approved transactions, the plan sponsor retains the paperwork; for pre-approved transactions, no paperwork is created at all. Submitting these requests wastes time and delays the audit. Auditors should first check the 'SUMM RULE' column on the Withdrawals or Loan Withdrawals Report and compare it to the Plan's Summ Rule Report to determine the transaction type before submitting any paperwork request, and should only request documentation from Fidelity for sponsor-directed transactions.
Auditors sometimes overlook the forfeiture account when reviewing the Balance Info Summary Extract (BISE) report, missing important activity such as unvested amounts forfeited by participants, funds used to offset contributions, or amounts used to pay plan expenses. The forfeiture account appears at the very bottom of the BISE report under SSN 999-99-9999F and is labeled 'FORFEITURE ACCOUNT.' Failure to review this account can result in incomplete audit coverage of plan assets. Auditors should specifically locate and review the forfeiture account in the BISE, and use the Audit Forfeiture Activity Report from Enhanced PSW® Reporting for detailed transaction-level review as described in Section 2.13.
Auditors often apply only the FWS DC Recordkeeping SOC 1 report to all plan investments without recognizing that different investment types require different SOC 1 reports. For example, plans with self-directed brokerage (SDB) accounts require the NFS SOC 1 report, while plans with non-registered Fidelity funds (such as MIP, MIP2, unitized stock funds, or synthetic GICs) require the FFIO SOC 1 report. Using the wrong SOC 1 report means key controls over certain investment types are not evaluated. Auditors should use the fund code table in Section 3.9 of the Auditor's Guide—where codes beginning with 'G' or 'T' indicate FFIO coverage and 'BLNK/BLNC' indicates NFS coverage—to determine which SOC 1 reports are applicable.
Some auditors still report participant loans at fair value in the plan's audited financial statements, which has not been required since the effective date of ASU 2010-25 for plan years after December 15, 2010. Participant loans must now be classified as notes receivable from participants and measured at amortized cost (unpaid principal plus accrued but unpaid interest), not as investments at fair value. This distinction also means ASC 820 fair value hierarchy levels no longer apply to participant loans. Note that Form 5500 Schedule H still requires participant loans to be classified as an investment on line 1(c)(8), creating a difference between the financial statements and the Form 5500 that must be disclosed.
Auditors and plan sponsors who rely on the legacy 'Run Reports' page in PSW® to generate audit-related reports may be caught off guard when this page is decommissioned in 2025, disrupting their ability to access needed reports during the audit cycle. All reports previously available on the 'Run Reports' page, along with additional features, are now accessible under 'Reporting' > 'Dashboard' in PSW®. Auditors should familiarize themselves with the new Dashboard interface and the Guide to Annual Audit Support Templates available on PSW® to ensure uninterrupted access to all required reports, including the Audit Contribution Summary, Deferrals Report, and Audit Forfeiture Activity Report.
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