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Sched H - Report delinquent contributions until Restored & Lost Earnings Deposited, or until VFCP?


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Posted

For reporting delinquent contributions, do they get included in successive years only until the late contributions have been deposited (recovery date), or do they keep getting reported until a VFCP is submitted?

Posted

The delinquent contributions are reported in each successive year if they were not fully corrected at any time during the plan year being reported.  They are not fully corrected until the contributions and all associated lost earnings are deposited into the plan.

Posted

Thanks!  I typed too fast, yes I meant to include late contributions AND lost earnings, but then was questioning once those are done but not the VFCP if the amount needs to be included on 5500's until VFCP done.

Looking to clarify definition of 'fully corrected'.

Posted

The 5500 instructions say:

"Plans that check “Yes,” must enter the aggregate amount of all late contributions for the year. The total amount of the delinquent contributions must be included on line 9a for the year in which the contributions were delinquent and must be carried over and reported again on line 9a for each subsequent year (or on line 4a of Schedule H or I of the Form 5500 or line 10a of the Form 5500-SF if choosing not to rely on a DCG Form 5500 filing to satisfy the plan’s reporting requirement in the subsequent year) until the year after the violation has been fully corrected by payment of the late contributions and reimbursement of the plan for lost earnings or profits. All delinquent participant contributions must be reported on line 9a at least for the year in which they were delinquent even if violations have been fully corrected by the close of the plan year."

There is no reference to whether or not a VFCP was filed.  The only requirement is the deposit of the late contributions and lost earnings.

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