Has anyone had a CPA request "ESOP Transaction Documentation" for a non-leveraged ESOP plan contribution?

If yes, what did you provide?

Hmm.... I guess I would just ask them what they are looking for. The auditor does have a duty to look at prohibited transaction implications. So, if cash was contributed to the ESOP which was then used to purchase stock, they might be looking for the details describing how that was handled. It is possible that they are just looking for the authorization of the transaction.

I am a CPA and work for an auditing firm. So, you have to take what I say in that context. But, auditors should explain themselves, just like they expect the TPA to explain themselves. So, just ask what they are looking for.