Small Benefits, De Minimis Exception

[Guest BWORC]

Here is my question: what is a "reasonable direct cost of processing and delivering the distribution" under EPCRS and the related "cost of making the distribution" under VFCP?

Under EPCRS, Rev. Proc. 2013-12, Section 6.02(5)(b).

under VFCP, Section 5(e).

Does this include the time spent in figuring out the amount of the distribution? Or does this calculation begin after all of the heavy lifting is done and you need to cut a check? If the distribution is to come from the plan, I suppose that normal TPA fees for making distributions would apply, but how about time spent by the employees of the plan sponsor? Attorney time in the application process?

I am not aware of any of these claims about the cost of cutting a check have been kicked back by either the IRS or DOL, but I don't want to find out the hard way.

Thanks.