What's the concensus here? (Late deposits)

Just wondering how everyone out here would view this:

Plan is a large employer.  There's a 50-on-5 match, payroll period basis.  Not safe harbor, and they do choose, operationally, to make the match deposits each week.

Everyone's deposits for 2017 were fine except somehow, an owner's missing one week's worth.  $375 in 401(k) deferrals and a $187.50 match.  (He's salaried and these amounts were consistent every week.)

If this were a small plan, they'd have the 7 business day safe harbor.  Since they are prompt with their deposits, there's at least some sort of argument that, "Hey, we *could* say one deposit was 30 weeks late.  Or we could say that the next 29 deposits were all 1 week late - but within 7 business days."

Anyway, that's not exactly where I'm going with this one - I would like to at least suggest that the fact that the guy's been getting match contributions all along, that those almost serve to "cover" the 401(k) amount due by the deadline for the deposit.

At no point during 2017, was his account underfunded relative to his payroll withholdings.  The plan sponsor has a requirement to keep pace with the funding of the deferrals, and not the match (which could be deposited up until tax filing day in 2018).

I suppose a potential snag is that if this "early money" went in before the paycheck that was missed, then it could be construed as accelerating funding of the plan.

Can you tell I'm trying to avoid reporting $375 on the 5500 and preparing a 5330?  :)
Thanks.

We have a compliance questionnaire where we ask the client to tell us if there were any late deposits.  Whether that is adequate "cover" or not, we've never had the misfortune to have it tested.  (But, if we can't help but know of egregious failures, we make them fix them.)  In this case, I have no problem playing the blind monkey.  And I think your approach of saying that if you had to you could slide money from one source to another works; we do that too.

I seem to recall hearing many years ago (and memories are a tricky thing) that people have tried versions of that argument to DOL auditors and failed. 

Life is a risk as long as people understand the risk decide.  

I would have treated the $375 as late and moved on. Why make the client's problem become your problem?  The lost income would be a small amount and the excise tax very small.  We don't do a 5330 if the amount is very small, we just have the client deposit the excise tax along with the lost income.  In this case, I'm guessing the excise tax would only be a couple of $.