Correction of Late Safe Harbor Matching Contributions Required?

[kmhaab]

I'm looking into whether correction under ECPRS is required in this situation and want to make sure I'm not missing something. 

A Safe Harbor plan makes Traditional Safe Harbor Matching Contributions. The AA says the safe harbor matching contributions are based on salary deferrals for the Payroll Period, instead of the Plan Year. The Basic Plan Document says the safe harbor matching contributions must be deposited into the Plan by the last day of the Plan Year quarter following the Plan Year Quarter for which the salary deferrals were made if the employer uses a period other than the Plan Year, which I believe reflects the regs. 

In operation, the plan has been depositing the safe harbor matching contributions into the plan at the end of the year - not be the end of the following quarter.

I believe this is an operational failure under ECPRS and must be corrected? The correction method being adjusting participants for lost earnings from the date the safe harbor matching contributions should have been contributed to the actual date they were contributed?

But the plan sponsor and recordkeeper see no issue, say the plan has been operating like this for a long time, and they have no concerns - Am I missing something?? TIA.