Late transfer to participant accounts

[Tom]

We have a small plan whereby each participant has a separate broker account.  We directed the financial advisor to deposit into each person's account their 2022 employer contribution in Sept 2023 and actually again in Feb 2024.  It did not get done until May 2024.  The contribution was made to the plan on time for tax purposes - deposited into a general fund plan .account.  The financial advisor has agreed to deposit lost earnings.

The FA is now getting into areas that in my opinion they should not -asking us if Form 5330 is needed and if the 2023 5500 needs to be amended to reflect the earnings receivable.  I do not see anyway to report this on Form 5330.  The employer did not benefit so it is not a prohibited transaction.   As for the 5500, I lean toward just showing the earnings on the 2024 5500 since that is when they will be deposited.  I suppose we could split our calculation between Oct 1 and Dec 31, 2023 and show that as a receivable and amend the 5500 but that seems unnecessary.  It is filed on an accrual basis since we add in the employer 2023 contribution receivable even though not paid until 2024.

Thoughts?

[Lou S.]

I'd vote with you. No 5330, reflect the earnings in 2024 when received.