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We would do that in a heartbeat.

I agree with MoJo--depending on the plan's history, this seems pretty de minimis and we would normally treat it as such. Amount is very small (depending on plan's size, regular contributions, participant account balances, other history etc.) and delay is very short.

While the DOL may not agree - the way I'd look at this is that the 7 day rule is a "safe harbor." The requirement is "as soon as practicable." If for reasons beyond the control of the employer it went that extra day, then it may be "as soon as practicable" even though it didn't meet the safe harbor. The DOL would look at the regularity of prior contributions - and in my experience would say if you can do it in x days, you should be able to do it in x days - so "as soon as practicable" to them is the pattern of behavior established. Conversely, if you do it consistently in x days, and ONCE do it in x-1 days, they have been know to hold you to the x-1 standard, and deem all other contributions as late.