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Posted

Sponsor of large 401(k) plan remitted deferrals and loan payments monthly, although payroll is biweekly.

So at least half of pay periods, amounts were remitted after 3rd business day following payroll.

We have calculated lost earnings on deferrals and loan payments using DOL's VFCP calculator.

We will prepare 5330, and sponsor will deposit lost earnings and pay excise tax.

Question: will the fact that the loan payments were remitted late to the plan change the outstanding balances on the loans?

The amortization schedules are based on biweekly payments, not monthly payments.

Thanks.

Posted

Please do as ERISA says. Don't make a mountain out of a mole hill. There is no penalty for making loan payments a few days late. If you insist on being picky, change all the future loan amortization schedules to monthly.

JanetM CPA, MBA

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