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Posted

Employer has several late remittances of deferrals to the trust.  Prohibited transaction.  Fix (perhaps) under VFCP.

 

Is it also an operational error?  Corrected under SCP?  If so, what "operation" under the plan doc did they violate?

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

Posted

Maybe there's something in the Contributions/Salary Deferrals section of the document that would address any timing of contributions rule inherent to the document itself, as opposed to an "outside" DOL rule?

Posted

I looked up "deposit" and "deposited" in the BPD and none of the hits were relevant to the topic.

I'll look further.

QKA, QPA, CPC, ERPA

Two wrongs don't make a right, but three rights make a left.

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