401(a) Deposit Deadline

[JustMe]

Is there a deposit deadline for employer contributions to a governmental 401(a) plan?  governmental 403(b) plan?

Thank you!

[Luke Bailey]

I don’t think there is for a 401(a) plan. 1.403(b)-8(b) says the deadline for contributions to a 403(b) is what is “reasonable.”

[JustMe]

Thank you for your response!

[Luke Bailey]

U R welcome, JustMe.

[Kevin C]

There is a limit on how late employer contributions can be deposited and still count as annual additions for the year. It includes a rule that applies to governmental employers.

 

Quote

1.415(c)-1(b)(6)(i)(B) Date of employer contributions. For purposes of this paragraph (b), employer contributions are not treated as credited to a participant's account for a particular limitation year unless the contributions are actually made to the plan no later than 30 days after the end of the period described in section 404(a)(6) applicable to the taxable year with or within which the particular limitation year ends. If, however, contributions are made by an employer exempt from Federal income tax (including a governmental employer), the contributions must be made to the plan no later than the 15th day of the tenth calendar month following the end of the calendar year or fiscal year (as applicable, depending on the basis on which the employer keeps its books) with or within which the particular limitation year ends. If contributions are made to a plan after the end of the period during which contributions can be made and treated as credited to a participant's account for a particular limitation year, allocations attributable to those contributions are treated as credited to the participant's account for the limitation year during which those contributions are made.

 

[Carol V. Calhoun]

Yeah, it depends on whether it is a defined benefit or defined contribution plan.  For defined contribution, contributions beyond the date specified by Kevin C would be treated as annual additions for the following year, which could potentially (depending on the amounts involved) create a 415(c) problem for the subsequent year.  However, for a defined benefit plan, there really is no limit, since governmental DB plans are not subject to funding requirements.