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Auditor Market Share of ERISA Benefit Plans

Entities, or sponsors, that offer post-employment benefit plans are required by ERISA (the federal Employee Retirement Income Security Act of 1974) to disclose audited financial information to plan beneficiaries. ERISA establishes the minimum standards for employment benefit plans, including pensions, 401(k) accounts, and health plans.

Each year, these plans must submit financial information to the IRS on a Form 5500, as well as adhere to Department of Labor reporting practices.

To ensure the accuracy of financials, these annual reports pertaining to benefit plans must be reviewed by an independent auditor. However, these are specialized audits, differing greatly from a standard audit of a public company’s financial statements. As such, certain firms have more representation in this particular audit market compared to the public company market.

Single Employer and Multi Employer ERISA Plans

The audit market for single employer and multi employer benefit plans is vast. Unlike the public company audit market, the benefit plan audit market encompasses a diverse array of firms. In 2019, 4,538 firms participated in audits of nearly 93,000 plans.

The top 20 firms, by the number of total plans audited, account for nearly 30% (28.4%) of the market. This suggests that these firms have a particular focus or specialty in the benefit plan market.

The top 10 firms each audited over 1,000 plans in 2019. CliftonLarsonAllen holds the top spot, auditing 3,128 plans during the year, or 3.36% of the market.

Drilling down further, the top 10 audit firms differ depending on the number of total plan assets.

For small benefit plans with less than $5 million in assets, the top 10 audit firms are similar to the overall benefit plan market breakdown. One exception is the Tennessee-based firm Coulter & Justus, who audited 86 benefit plans in 2019 with assets under $1 million.

As the amount of plan assets increases, the top audit firms shift. The audit market of benefit plans with assets under $1 billion almost exclusively consists of firms outside the Big Four. In contrast, in the audit market for very large benefit plans – with assets over $1 billion – the Big Four dominate. This encapsulates employee benefit plans offered by very large employers.

For example, the top five plans, by amount of assets, include: The Boeing Company Voluntary Investment Plan, IBM’s 401(k) plan, General Motors Hourly-Rate Employees Pension Plan, AT&T/WarnerMedia Pension Benefit Plan, and IBM’s Personal Pension Plan. Each plan had over $50 billion in assets at the end of 2019. The Big Four audited four of those plans, joined by Mitchell & Titus, a member firm of BDO Alliance USA.

Direct Filing Entity ERISA Plans

Apart from standard pension plans, other arrangements also require a Form 5500, referred to as direct filing entities (DFEs). Often, this relates to a pooled investment arrangement; for example, a trust or a group insurance arrangement with a plan that provides benefits to employees across multiple, unaffiliated employers.

In comparison to single and multi employer benefit plans, the DFE benefit plan market is more concentrated. The Big Four hold 73.4% of that market, with PwC and KPMG each holding around one-quarter.

In conclusion, sponsoring health and retirement benefit plans for employees is critical to maintaining a strong, competitive workforce for any organization. Therefore, it is critical that a qualified and experienced audit firm assess and review a company’s ERISA benefit plan’s financials and regulatory filings.

This analysis uses 2019 data from the ERISA database, powered by Audit Analytics, and is based on auditor data pulled in December 2021.

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