EPCRS - earnings, "lag time" in deposit

[t.haley]

I am looking for some guidance on how to address the calculation of earnings on a QNEC, specifically how to handle the calculation of earnings for the lag time between the funding of the QNEC and when it actually hits a participant's account.  I am being told by the record keeper that there may be as much as a 3-5 day lag between the time the employer's bank account is debited for the QNEC (plus earnings thru that date) and when it actually is deposited in the participant accounts.  They propose calculating earnings up to the day the money leaves the employer's account.  I read EPCRS to require earnings up to the date the "contribution is made" to the participant account.  For some reason they are balking at carrying the earnings calculation forward to account for this possible lag time.  It would be helpful to provide them with some official guidance, etc. addressing this.  Any help would be appreciated!

[BG5150]

I seem to remember reading that the earnings need to be deposited within 5 business days after the calculation date, but I cannot find that in EPCRS. 

[t.haley]

BG5150 - I have searched EPCRS too for some kind of qualifying language to address this but have come up empty-handed also!

[BG5150]

But I know I saw it somewhere.