Structured for Compliance.
Designed for Solutions.

Independent advisory at the intersection of ERISA, federal tax, and fiduciary oversight.

Independent analysis.
No products.
No commissions.

Covenant Compliance Group is an independent advisory firm operating at the intersection of ERISA, federal tax, and fiduciary oversight. The firm is structured to support internal decision-makers and external advisors in evaluating the design, documentation, and compliance posture of employee benefit programs.

Our work product is intended to withstand review by ERISA counsel, tax advisors, auditors, and regulators. We do not sell insurance products, receive carrier commissions, or accept implementation-based compensation of any kind.

This structural independence is not incidental. It is the foundation of every engagement and the basis upon which our conclusions are offered.

The firm serves chief financial officers, general counsel, ERISA attorneys, tax advisors, and independent auditors — professionals who require analysis that is neutral, precise, and technically supportable.

Three disciplines. One objective.

Employee benefit structures — particularly those outside traditional fully-insured models — can introduce meaningful legal and tax exposure. Our role is to evaluate whether those structures are technically supportable, clearly documented, and appropriate for regulatory scrutiny.

I

Structural Evaluation

Review of plan design, documentation, and operational compliance against applicable ERISA, IRC, and DOL requirements. We identify structural deficiencies before regulators and auditors do.

II

Tax Position Analysis

Evaluation of employer and employee tax treatment, including Section 125 cafeteria plan compliance, IRC Section 105/106 positioning, payroll tax implications, and documentation sufficiency for audit defense.

III

Compliance Readiness

Preparation for regulatory inquiry, audit examination, and fiduciary challenge. We evaluate whether an organization's benefit program posture can withstand adversarial review — and document the basis for that conclusion.

"The question is not whether a benefit structure will be examined — it is whether the documentation will support the position when it is."

Deliberate. Documented.
Defensible.

Every engagement follows a structured methodology designed to produce work product that serves as a contemporaneous record of compliance analysis — not a sales document.

01

Intake & Document Review

Comprehensive review of existing plan documents, summary plan descriptions, adoption agreements, IRS determination letters, Form 5500 filings, and prior audit correspondence. We establish the factual record before forming conclusions.

02

Structural & Tax Position Mapping

Identification of the legal and tax framework applicable to the plan structure, including ERISA coverage requirements, IRC compliance provisions, and applicable DOL guidance. Each structural element is mapped to its regulatory basis.

03

Gap Analysis & Risk Identification

Systematic identification of documentation gaps, operational inconsistencies, and compliance exposures. Findings are categorized by severity and presented with specific regulatory citations.

04

Deliverable & Position Documentation

Production of a written analysis suitable for review by internal counsel, external ERISA advisors, tax professionals, and — if necessary — regulatory authorities. All conclusions are supported by specific statutory, regulatory, or administrative authority.

Our conclusions are not for sale.

Covenant Compliance Group does not receive commissions, implementation fees, or referral compensation from insurance carriers, brokers, or plan administrators. This is a structural choice, not a marketing position.

The absence of product-based revenue ensures that every analytical conclusion reflects technical merit alone — a distinction that matters when the audience is opposing counsel, a DOL investigator, or an IRS examiner.

No Carrier Commissions

No Implementation Fees

No Referral Revenue

Fee-Only Advisory

The cost of
unexamined structure.

Employee benefit programs that operate outside traditional models often proceed without the level of structural and tax analysis that their risk profile demands. The consequences of that gap tend to surface at the worst possible time.

  • IRS reclassification of employer-sponsored benefit arrangements, resulting in retroactive payroll tax liability and penalty exposure
  • DOL enforcement actions arising from ERISA fiduciary breaches, inadequate plan documentation, or operational failures
  • Audit findings that reveal structural deficiencies in plan design, triggering correction obligations under EPCRS or VCP
  • Litigation exposure from plan participants challenging the adequacy of disclosures, the fairness of plan terms, or the prudence of fiduciary decisions
"The objective is not to validate a decision that has already been made. It is to evaluate whether the structure, as designed and operated, is defensible."

Covenant Compliance Group exists to answer that question before the examination begins. Our engagement model is designed to produce the kind of analysis that a CFO can hand to outside counsel, a general counsel can present to the board, and an ERISA attorney can rely upon in defense of a plan's compliance posture.

The work product is not a summary. It is not an opinion letter dressed as marketing. It is a structured, documented, and citable evaluation of compliance posture — one that treats every regulatory question as though it will eventually be asked under oath.

IRS discipline.
Litigation-tested counsel.

Covenant Compliance Group was founded by practitioners whose professional experience encompasses the regulatory and legal environments in which employee benefit compliance questions are ultimately resolved.

Tax · Advisory · IRS

Matt Klingeman, CPA

Principal — Tax & Structural Advisory

Matt Klingeman is a certified public accountant and former IRS manager with more than twenty years of experience in tax and accounting. He began his career at the Internal Revenue Service, where over an eight-year tenure he managed examinations of small businesses, complex individual returns, large partnerships, and multinational corporate audits.

At the IRS, Matt led national projects targeting abusive transactions and transfer pricing — experience that now informs his approach to evaluating the tax defensibility of employee benefit structures. He understands what the Service looks for, how examinations are conducted, and what documentation is required to support a position under audit.

  • Former IRS Manager — 8 years
  • Small business, partnership, and multinational corporate examinations
  • National projects — abusive transactions, transfer pricing
  • Master of Science in Taxation
  • 20+ years CPA practice

ERISA · Litigation · Corporate

Erin Jensen, J.D.

Principal — Compliance & Legal Advisory

Erin Jensen is a commercial litigator and transactional attorney whose practice encompasses complex commercial litigation, corporate law, and regulatory compliance. He previously practiced in the Colorado Springs and Denver offices of Hogan & Hartson — now Hogan Lovells — one of the largest and most recognized law firms in the world.

Erin's litigation background provides Covenant's compliance analysis with the adversarial perspective that regulatory defense requires. His work evaluating fiduciary obligations, structural integrity, and documentation precision reflects the standard of scrutiny that ERISA counsel, auditors, and regulators apply.

  • Former Hogan & Hartson (now Hogan Lovells)
  • Judicial clerkship — Hon. Daniel V. Zemaitis
  • J.D., Magna Cum Laude — Michigan State University College of Law
  • Admitted: Colorado Supreme Court, U.S. District Court (D. Colo.), U.S. Court of Appeals (10th Cir.)
  • Complex commercial litigation and corporate transactions

Begin with a conversation.

Engagements begin with a confidential, no-obligation consultation to determine whether Covenant's advisory scope is appropriate for your organization's compliance requirements.

Request a Consultation