Structuring Retirement Plan Internal Controls Amid Heightened IRS and DOL Scrutiny

Avoiding Violations with Plan Amendments, Target Date Funds, Investment Manager Agreements, Discrimination Testing and More

Recording of a 90-minute premium CLE/CPE webinar with Q&A

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Conducted on Wednesday, June 4, 2014

Recorded event now available

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Course Materials

This CLE course will provide ERISA counsel and advisors with the tools necessary to structure internal controls that mitigate expanded IRS and DOL audits. Our experienced panelists will provide best practices to avoid violations with plan amendments, target date funds, discrimination testing and more.  


The IRS initiated an enforcement campaign focused on plan sponsors’ internal controls in administering its tax-qualified retirement plans. The IRS has made it clear that by having a detailed control system, plan sponsors can avoid expanded audits. ERISA counsel should offer guidance to clients on processes that have been shown satisfactory in an IRS audit.

The sometimes more difficult and burdensome DOL audit focuses on proper plan practices and procedures. Without proper controls in place and implemented, plan sponsors can expect to face more scrutiny from the DOL auditor. One of the DOL's substantive areas of concern are the popular target-date funds for which the DOL recently issued guidance for plan sponsors.

Listen as our panel, experienced in DOL and IRS audits of retirement plans, highlights substantive areas of focus for both agencies. The panel will also provide specific guidance in establishing internal controls to address these areas and conducting internal preventive audits. Our authoritative panel will outline the substantive requirements for sponsors, identify common errors, and provide solutions for addressing and correcting problems before an audit occurs.



  1. Overview of internal controls
  2. IRS audits
    1. Definition of Compensation
    2. Plan amendments
    3. Eligibility
    4. Loans
    5. In-service distributions
    6. Suspension of benefits
    7. ADP/ACP Testing
  3. DOL audits
    1. Target date funds
    2. Consultant/investment manager agreements
    3. Float
    4. Revenue sharing/12b-1 fees


The panel will answer the following questions:

  • How must plan sponsors implement internal control processes for tax-qualified retirement plans?
  • What substantive areas are of concern to the IRS and DOL? 
  • What specific processes should be in place to minimize violations in IRS and DOL areas of concern?
  • What should plan sponsors consider when reviewing investment manager agreements and revenue sharing arrangements?


Mary Andersen
Mary Andersen


Ms. Andersen, CEBS, ERPA, QPA, has worked in benefits consulting and administration over 25 years. Her experience...  |  Read More

Nancy S. Gerrie
Nancy S. Gerrie

McDermott Will & Emery

Ms. Gerrie works with corporations, partnerships, LLCs and tax-exempt entities on a variety of retirement plan and...  |  Read More

Jeffrey M. Holdvogt
Jeffrey M. Holdvogt

McDermott Will & Emery

Mr. Holdvogt advises clients regarding a variety of employee benefits matters. His practice focuses primarily on the...  |  Read More

Howard Pianko
Howard Pianko

Seyfarth Shaw

Mr. Pianko advises on the full gamut of matters relating to employee benefits, including pension and welfare benefit...  |  Read More

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