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I was trained that a deposit made before the actual paycheck date was considered to be an employer discretionary contribution, not deferrals.

I don't know if it has come up before. I think what you are proposing is fine, but for a different reason than the one you are suggesting. Even assuming for the sake of argument that the IRS' position is correct, this is not a "forfeiture." A forfeiture results from an allocation required under the terms of the plan which was subject to a vesting condition, i.e., a risk of forfeiture. While we call these corrections of impermissible allocations "forfeitures," they are not forfeitures.

If you are "considered the plan administrator for certain functions", then you have probably already taken on some liability for which you could be personally held accountable. That's the POINT to being a 3(16) Plan administrator. You agree to take on the RESPONSIBILITY and the LIABILITY that comes with the various functions. It is more than just an administrative convenience for you to approve distributions and monitor payroll. If you are truly concerned about the exposure, perhaps you should not have entered the 3(16) "space" to begin with. I would immediately seek ERISA counsel to determine what your liability is and assess your risk tolerance thereto.