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Are Participant Contributions Remitted Quickly Enough? Proposed Safe Harbor for Small Plans and Implications for Large Plans (PDF)
Drinker Biddle
[Guidance Overview] Mar. 6, 2008
2 pages. Excerpt: No safe harbor has been proposed for plans that have 100 or more participants at the beginning of the plan year. However, the DOL states that smaller plans 'typically need more time than larger plans to segregate participant contributions from their general assets.' This suggests that if a safe harbor were proposed for large plans, it would require payment to the large plan in fewer than seven business days from the date of receipt or withholding.
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