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Assume a different plan that has always filed the 5500 on a cash basis. On the account statements, 120 participants have an account balance consisting of actual funds as of 12/31/2022. The plan sponsor deposited an employer contribution on April 1, 2023 for the 2022 plan year. There were two participants who had been paid out prior to 12/31/2022, who received a contribution. There is no actual money in their account. Their account consists of a receivable. As of 1/1/2023, 122 participants have an account balance if you include the receivable. My thought is even though you file on a cash basis, the participants should still be counted and the plan would be audited. Is that correct?

If plan reporting is done on a cash basis, is the answer still the same? I am thinking the answer is still the same. Regardless of whether reporting on a cash or accrual basis, the participant has an account balance. Thoughts?

If correct by filing the Form 5330 and paying the excise tax, can the DOL calculator be used to determine the earnings? A VFCP filing will not be done. I have seen where some people use the DOL calculator even when the VFCP filing will not be done. I have also seen where it is indicated that the DOL calculator cannot be used if not filing under VFCP. What are people actually using to determine earnings on the late deposits?