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Guest GMMartellacci

Contribution Remittance

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Guest GMMartellacci

I have a client who historically has remitted their contributions 4 to 5 days after the pay date. There were a few occasions this year where they made the remittance the day after the pay date. Since there were a few occassions that they remitted the contributions the following day, do I need to use the one day remittance as my benchmark for the entire year? Or can I used the one day remittance as a benchmark from the day it occurred on?

Also, I am aware of the safe harbor rule that was finalized in January of 2010. When it says fewer than 100 participants at the beginning of the year, does it mean active participants or all of the participants in the plan as stated by the Form 5500?

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