Does the audit committee of the plan sponsor of an employee benefit plan have to pre-approve the audit of the plan?
No. The Commission’s independence rules (2.01(c)(7)) require pre-approval of services provided to the issuer and the issuer’s subsidiaries, but not pre-approval of services provided to other affiliates of the issuer that are not subsidiaries. Therefore, the independence rules do not require the audit committee of the plan sponsor to pre-approve audits of the employee benefit plans. Audit committees however, are not precluded from establishing policies to do so.
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