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Timing of Plan Contributions - Safe Harbor Myths and Truths
Poyner Spruill
[Guidance Overview] Aug. 12, 2008 Excerpt: Desiring certainty on the timing question and hoping to boost compliance, the DOL recently proposed a new regulation that would give small pension and welfare plans (plans with fewer than 100 participants at the beginning of the plan year) a seven-day safe harbor for depositing participant contributions to a plan. Under the proposed safe harbor, the employer would have seven business days to transmit participant contributions even if the employer could reasonably do so sooner. The seven-day safe harbor period would begin on the first business day after the amounts would have been paid to the employee had they not been withheld from his or her pay. MORE >> |
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