The amounts will be rather small - around $50 per participant. This is a small plan, as well. The amounts are associated with delayed contributions as far back as 2010, but most pertain to the 2012-2013 time frame. Does that change the analysis at all?
Should we send a letter to all current Plan participants to describe the nature of the lost earning contribution?
It looks like the credited response is to contribute the amounts directly into the participant accounts who were eligible and participating at the time that the earnings should have been received, and send checks to last known addresses for former participants. Is the roll over letter required for all former participants?
Also, are the Form 5330 excise taxes triggered?