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  1. Takeover plan was being done in house (no tpa). Reviewing 401(k) deposits back to 2011 (2010 5500 is last to report delinquent contributions). 2011-2013 as large plan did not file audit report, and will not pay for audit report now In 2014 plan went from large to small Average delay from payroll date to deposit date from 2011-2013 is 35 days, though one time they deposited in 6 days. Contemplating the following: -how many years to review? to 2011, or back 3 years? -apply small plan safe harbor of 7 days to analyze large plan timing, or apply 6 days or 35 days or until 15th of following month for that period? A thought would be appreciated:)
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