Recently, the Treasury Inspector General for Tax Administration released an audit report on the Internal Revenue Service (IRS) Employee Plans oversight program for nonbank trustees and custodians (NBTs). NBTs are entities other than banks and insurance companies that are authorized by the IRS to act as trustees or custodians for certain retirement, health and education savings arrangements. As described in the audit report:

- In the aftermath of the Madoff scandal, the IRS ascertained that a Madoff entity had been approved as an NBT.

- As a result, the IRS undertook to:

-- Strengthen its processes for evaluating new applications to serve as an NBT. The processes include at least an updated and standardized form of internal IRS documentation, referred to as the Nonbank Trustee Approval Checklist/Workpaper Exam Investigation; and ...

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