Prohibited Transaction

[J. Bringhurst]

Obviously, participant contributions/loan repayments that are not timely remitted to a plan's trust (i.e., as soon as administratively practicable) are a prohibited transaction and, if the time period for remitting such contributions to the trust is specified in the plan document, an operational failure to follow the plan's terms.

What if a plan specifies the time period (e.g., monthly) for remitting matching contributions and that period is not met? It's an operational failure to follow the plan's terms, but is it also a prohibited transaction (i.e., impermissible extension of credit)?

Are most out there fixing the prohibited transaction issue through VFCP, Form 5330 or both?