Deferrals deposited late - earning calculations and 5500 relation

Apologies for the 100 level questions as my first time doing this.

Client made the 2019 deferral deposits pretty much 15-30 days after the payroll dates.

Assuming 7th business day as the safe harbor deposit date. Document is silent on when the deposits need to be made. This seems to be the standard. I am aware of the "as soon as feasible" clause which varies from employer to employer.

My understanding from the VFCP section 5(b) and the questions based on the "online calculator" page

• Principal amount is the per payroll deduction e.g. 3/1/19 for $200
• Loss date is the 7th business date from payroll date 3/11/19 (included 3/1 as the first business date)
• Recovery date is the date of the deposit 3/18/19 i.e. 6th business days from loss date
• Final payment date - assuming the same as Recovery date - I could not find anything on this as a definition.

Questions:

•  Are the dates correct as calculated above?
• The interest added by the employer to make up the missed dates, are they deductible. If yes which year (assume 2019 tax return not yet done)
•  As this additional interest correction added to the assets, for which plan year's 5500 filing should reflect them? Assume 2019 5500 filing is not yet completed.
•  What if during 2019 assets had a negative return or 25% return, does it matter how the assets perfomed? 

Any comments/suggestions are appreciated.

Thank you,

As a follow up, is there a de minimus amount of interest? I used the calculator based on above assumptions and got 23 cents of interest. How to tell a client to make the 23 cents of deposit.

Thank you

I recommend you read the instructions on the site. The definitions are under the "Glossary" section.

Recovery Date - The date that the Principal Amount is restored to the plan.

Final Payment Date - The date on which Lost Earnings is paid to the Plan, if later than the Recovery Date.

Thank you for pointing out the glossary section.

How about the other points like deductibility etc.

Jakyasar, the amounts paid to the plan as interest should be deductible in the same way and on same deadlines, and subject to same restrictions, as contributions.

Thank you Luke.