What happens if SHM is "late"?

Payroll-based SHM is not deposited by the end of the quarter after the deferrals were taken.  

What are the consequences?

The plan admin is tarred and feathered...

...Unless you make the participants whole by allocating lost earnings.  EPCRS principles of correction would apply.  You do not lose SH status if you correct.

Depends on what the document says. If the document says that contributions will be deposited quarterly then you have an operational failure and need to self correct under EPCRS. If it says the match will be deposited "at a time to be determined by the plan administrator" or other such language then you would true it up at the end of the year. Of course the match would have to be computed based on the whole year in this case.

Yeah, but if it's payroll-copmuted match, you have to do it quarterly - should be in the doc to that extent.

7 minutes ago, Bri said:

Yeah, but if it's payroll-copmuted match, you have to do it quarterly - should be in the doc to that extent.

The cite for anyone who wants it is 1.401(k)-3(c)(5)(ii). You have until end of following quarter.

Extending the question, what if the SHM is not payroll-based, and still deposited after due date of 5500 with extension?

I think that's a deduction and maybe a 415 issue.

8 hours ago, SoCalActuary said:

Extending the question, what if the SHM is not payroll-based, and still deposited after due date of 5500 with extension?

8 hours ago, BG5150 said:

I think that's a deduction and maybe a 415 issue.

Correct.  We have had a few good threads on it before.

The cliffs notes version (2018 calendar year plan):

• After 9/15 but no later than 10/15 - 2018 for 415 purposes but a 2019 deduction
• After 10/15 but no later than 12/31 - 2019 for both 415 and deduction
• After 12/31 - EPCRS puts you back in 2018 for 415 purposes but 2010 deduction (Rev Proc 2019-19 Section 6.02(4)(b), Treas. Reg. 1.415(c)-1(b)(6)(ii)(A))