I'm trying to get a CPA firm to change it's PVAB reconciliation from 1/1/2002 to 1/1/2003 to 1/1/2001 to 1/1/2002 for a report accompanying a 2002 Form 5500.

My experience is that years ago all CPAs reported a reconciliation to the valuation date ocurring 1 day after the audit year, but that over the years most changed to a reconciliation to the valuation date falling within the audit year.

I have an auditor balking at such change, asking for a legal or regulatory cite or justification for such a change. Does anybody know these rules or how they are found?

I thought this is entirely within the auditor's discretion. However, the auditor should probably investigate whether this is addressed in AICPA guidelines, such as with respect to SFAS No. 35, or DOL audit guidelines.

I've seen both. Consistency is probably important.

Thanks, pax, your references are helpful. SFAS35 clearly says it can be done either way, and even implies that the way I'd prefer it be done is the better approach due to timing. But I haven't yet found anything that discusses making a change. Still reading on.