During a webinar today some ERISA attorneys said:
1. DOL is looking for 3 days max from large employers
2. DOL also looks at "quickest" instance as the benchmark, so be careful that the employer doesn't hurry up and one time fund 1 day after pay date
For what it's worth...
I'm curious about this part of your post. If the US Company is the sponsor of the plan, are you saying the company should not be named the Plan Administrator? If so, why?