Schedule H, Lines 4a and 4d -- What is "amount" of late defe

[Guest CMC]

It appears that an employer that fails to timely remit elective deferrals must, among other things, answer Lines 4a and 4d of Schedule H to Form 5500 in the affirmative and supply an "amount" for each line.

My question is about the "amount" (which I gather would be the same for each line). Is this amount equal to (1) the amount of the late elective deferrals or (2) the fair market value of the use of those late deferrals from the time they were late to the time they were deposited (i.e., the "interest" due on the prohibited "loan" from the plan to the employer) as with the amount listed in Line 26b, Column © of the Form 5330?

Any thoughts would be very much appreciated.