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Help is exactly what you need, but not the kind offered here. You need to talk to your employer and ask them who you can speak to at Wells Fargo that will explain basic investment issues. It matters TREMENDOUSLY which fund you go into; currently it seems that your funds are going into the Target retirement fund you mentioned, but you most likely have a number of alternative choices with the target fund probably being the default. Find out who at WF is available to provide some employee education, which is what you clearly need.

What do BenefitsLink people think about these questions: 1. Which recordkeeper/custodians accept a pending-blackout deposit? Which don’t? 2. How much about this point should a plan’s fiduciary check before selecting a recordkeeper? 3. Is there a plan size so small that even a prudent fiduciary would be unlikely to find a recordkeeper willing to accept the pending-blackout deposits?

It seems to me - if it is reasonable to retain this trustee - the trustee will not accept a contribution during a black-out period and - the length of the black-out period is reasonably short, then "the earliest date on which such contributions or repayments can reasonably be segregated from the employer's general assets" and transmitted to the trustee is the first full business day after the black-out period ends regardless of the employer's previous history of being about to transmit contributions sooner under a different set of circumstances. Whether the plan auditor will accept that argument, I do not know.

Choice of a vendor or a secure place to timely deposit this money is the plan sponsor's responsibility. Setting up all the details of this conversion should have included this issue. The vendor is pushing your client around because no one went over this with them when the deal was done (before they were hired). PNJ

Auditors will demand you report contributions delayed during a blackout as late. I believe the AICPA guidance that governs benefit plan audits would require that. Without DoL guidance to contrary, you will lose this battle every time.

We literally this month had an auditor of one of our plans raise this issue and "demand" it be corrected (and the box on the 5500 checked) before issuing their opinion. Theoretically, I agree - late is late, but 1) the rule is as soon as practicable (and that is open to debate as to what constitutes practicable) and 2) the rule requires segregation from corporate assets - as Peter says, and not "investment" - so the temporary account seems to be the best approach (although, IMHO, that is really rather stupid - as the change in recordkeeper or other reason for the blackout is pursuant to a "fiduciary" decision where their are benefits that should outweigh a slight delay - in other words, "practicable" is, and should be a FIDUCIARY decision....)

Treating an amount as plan assets does not necessarily mean the amount must be immediately invested in its ultimate-destination investment. Would an experienced fiduciary considering “the circumstances then prevailing”—including the blackout (if that decision was not a breach)—find it prudent to hold the pent-up amounts in a temporary account? Is it feasible to pay the amounts from the employer’s account and into an account the plan’s trustee holds (whether directly or through its agent)? After the blackout clears, the plan’s fiduciaries would allocate the temporary-holding amounts to investments as the participants directed (or as the plan otherwise provides).

Without knowing why the plan might not be qualified (and therefore not knowing ways it might be corrected to be qualified) I have no opinion. You're giving a tiny bit of information and asking for solutions to what is really an unknown problem. In any event it's probably above my pay grade, or at least something I would advise the client to hire an ERISA attorney to fix, especially if I had nothing to do with creating the problem.