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Plan Sponsor recvd EBSA ltr to file VFCP for late 401k as reported on 2011 5500. When I looked at 5500, delinquent amount reported includes only 401k, not loan pymts which were paid simultaneously. Considering correction approaches:

option 1: file vfcp based on reported amount of 401k

option 2: amend 5500 to add delinquent loan pymt amts and incorporate that into vfcp

thoughts much appreciated :).

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