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Employee Benefit Plan Audits

ERISA Section 103(a)(3)(C) Audit

Modus helps you get an ERISA Section 103(a)(3)(C) audit that meets DOL requirements, faster.

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An ERISA Section 103(a)(3)(C) audit is the option, formerly called a limited-scope audit, available when a qualified institution certifies a plan’s investment information, and Modus helps sponsors get that audit done faster and with less friction. With Modus, your 103(a)(3)(C) audit gets top-firm rigor and AI-native speed on your timeline.

What is an ERISA Section 103(a)(3)(C) audit?

An ERISA Section 103(a)(3)(C) audit is a permitted type of employee benefit plan audit in which a qualified institution, such as a bank or insurance carrier, certifies the completeness and accuracy of the plan’s investment information. The certified investment information is not audited, but substantial required procedures still apply to contributions, distributions, participant data, and the certification itself, and a specific form of report is issued.

This is not a lesser-quality or opinion-free audit. It is a full audit under a specific reporting framework, and the auditor still performs extensive work outside the certified investments.

Who needs an ERISA Section 103(a)(3)(C) audit?

This option is available to plans whose investments are held and certified by a qualified institution, and it is elected by the plan administrator.

  • Plans that otherwise require an audit at 100 or more participants.
  • Plans whose investments are held by a qualifying bank, trust company, or insurance carrier.
  • Sponsors who obtain a proper certification meeting DOL requirements.
  • Administrators who elect this scope rather than a full-scope audit of all investments.

What an ERISA Section 103(a)(3)(C) audit covers

  • Contributions, distributions, loans, and forfeitures.
  • Participant eligibility, enrollment, and census data.
  • Verification that the certification is proper and from a qualified institution.
  • Presentation and disclosure of the certified investment information.
  • Internal controls and compliance with the plan document.

How Modus helps with your 103(a)(3)(C) audit

Modus helps you get your ERISA Section 103(a)(3)(C) audit done at the speed of business. Its AI-native platform automates the most time-intensive fieldwork and validates the certification and non-investment areas efficiently, which is how a Modus-supported audit can target a turnaround of roughly four weeks. Workpapers are source-linked, so each figure traces back to its supporting document.

That efficiency changes your experience. Modus’s platform cuts the document requests and questions your team fields, so your finance staff spend less time servicing the audit.

Why choose Modus

  • Top-firm audit rigor at a middle-market price.
  • A target turnaround of roughly four weeks to keep your Form 5500 deadline comfortable.
  • Source-linked workpapers for full traceability outside the certified investments.
  • Up to roughly 50% fewer questions for your team during fieldwork.

Frequently asked questions

Is a 103(a)(3)(C) audit lower quality than a full-scope audit?

No. It is a full audit under a specific reporting framework. The certified investment information is not audited, but substantial procedures still apply to everything else, and a defined form of report is issued. The distinction is scope, not quality.

Who can provide the certification?

The certification must come from a qualified institution, such as a bank, trust company, or insurance carrier that holds the plan’s investments, and it must meet DOL requirements for completeness and accuracy. Confirming a proper certification is one of the first steps in the engagement.

When is the audit due?

The audited financial statements attach to your Form 5500, generally due seven months after the plan year-end, extendable by two and a half months via Form 5558. Starting early leaves room for a clean, unhurried process.

Why Modus

Audits at the speed of business

Modus helps you get a faster, higher-quality ERISA Section 103(a)(3)(C) Audit — top-firm rigor, source-linked workpapers, and far fewer questions for your team.

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