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Plan Sponsor's Deferral and Loan Payments for 7 payroll periods were deposited late. Payroll periods start in March and end in May. This occurred when the Plan Sponsor changed HR management and went unnoticed until the plan's investment platform sent an alert regarding a late loan repayment issue. All 7 payroll periods were deposited immediately when this was realized, all were within 75 or fewer days of when they should have been deposited but for the oversight. The Recovery Date is June 13. Amounts involve about $5,800 in total deferral deposits (aggregate all payroll periods) and $100 in loan repayments (aggregate). This is a self directed plan and 20 participants are affected. This oversight was addressed immediately and steps/protocols were established to prevent this from happening in the future. This is a Prohibited Transaction but not an operational defect as the plan does not specify a deposit date for deferrals. Questions: Lost Earnings: it is my understanding the Employer may determine Lost Interest (from date deposits should have been made (usually 1 day after payroll date) to actual Recovery Date) based on the greater of the (i) DOL Calculator or (ii) the Plan's actual "Investment Experience" had the deposits been timely made*. *To determine the "Investment Experience" it is my understanding the Employer may use the highest performing investment offered within the Plan, for each of the affected payroll periods in lieu of determining each participant's Investment Experience for each of the periods, if doing it individually is more costly than the benefit itself. The measurement period is the date the deposit should have been made, i.e. the Loss Date, to the Recovery Date (date actually deposited). IS THIS CORRECT? Interest on Lost Earnings: are determined from the Recovery Date to the Final Payment Date (the date the Lost Earnings are actually deposited along with interest on the Lost Earnings). DOL Calculator determines this easily using the DOL rates. HOW WOULD YOU DETERMINE THE INTEREST ON THE PLAN'S "INVESTMENT EXPERIENCE" LOST EARNINGS (referring to the greater of (i) DOL or (ii) Plan in #1 above)? Select a reasonable interest rate, e.g. Prime +1%? I read a post that suggested If the Employer were to determine the "Lost Earnings" and the "Interest on Lost Earnings" correctly (as above) and opted not to submit VFCP, it should be acceptable (no action nec) if ever audited since the Employer made the correction using the greater of the DOL or Plan Experience determination. IS THIS CORRECT? If submitting VFCP the Employer can use the DOL Calculator and ignore the plan's Investment Experience - correct? Restoration of Profits: is this an amount equal to a reasonable rate of interest (e.g. prime + 1%?) accumulated on each PT (i.e. each payroll period), measured from the Loss Date to the Recovery Date? If this cumulative amount is greater than the Lost Earnings determined as described above, then this amount should be remitted to the Plan in lieu of the Lost Earnings as determined above (and the Interest to the Final Correction Date is likewise adjusted)? Form 5330: essentially the Employer must pay a 15% excise tax for 4975 PT, and it is equal to 15% of the Lost Earnings amount (or Restoration of Profits amount if greater)? If the 15% Excise Tax is less than $100, the Employer may opt to deposit it into the Plan and allocate it to the affected participants (as per plan provisions)? Notice Affected Participants: is not necessary if the 5330 excise tax is deposited into the Plan and allocated to the affected participants in lieu of submitting Form 5330 and paying the tax? Are there any further corrective steps necessary? Should the VFCP submission be completed in spite of the small amount involved? Again, I thought I read a post indicating not to submit if the cost to prepare the submission exceeds the correction necessary. But of course the Employer must be certain all is calculated correctly and the correction is the greater of the DOL calc amount or the plan experience... Thank you.