Must an Independent Qualified Public Accountant (IQPA) verify that elective deferrals are deposited by the deadline?

Yes. The 2003 Form 5500 instructions require that an IQPA verify the timely deposit of elective deferrals. The good news is that third party administrators won't be placed in an awkward situation. The bad news for plan sponsors is that even one late payment (even if the delay was reasonable) will now likely be reported on the 5500 by the IQPA.

Are all plans filing a Form 5500 required to provide an IQPA audit verification of their elective deferral deposits?

All plans that are subject to an IQPA review must have their elective deferral deadlines verified by an IQPA. However, small plans (generally, plans with fewer than 100 participants) that are not subject to an IQPA audit (small plan audit rules) do not have to provide verification of the timely deposit of elective deferrals. If you would like more information on this and other Form 5500 issues, check into our eSeminar on this timely subject. See below for information.