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Are late deposits of deferrals considered an operational error?

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Employer has several late remittances of deferrals to the trust.  Prohibited transaction.  Fix (perhaps) under VFCP.


Is it also an operational error?  Corrected under SCP?  If so, what "operation" under the plan doc did they violate?


Two wrongs don't make a right, but three rights make a left.

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Maybe there's something in the Contributions/Salary Deferrals section of the document that would address any timing of contributions rule inherent to the document itself, as opposed to an "outside" DOL rule?

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