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Timely Payment of Employee Contributions


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Under the ERISA plan asset regulations, amounts withheld from a participant's wages for contribution to a plan must be paid to the plan within a certain period of time. Are there any similar rules for a church plan, which is not subject to ERISA?

For example, if a church employer withholds amounts from its employees' wages for their contributions to the church's medical plan and 403(B) plan, is there any time limit within which the church must pay those amounts to the plan? If not under ERISA, is anyone aware of any state's laws that would apply?

Who could be liable for the failure to pay the contributions in a timely manner--the church only, or could officers of the church be individually liable?

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