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Contribution of Deferrals Is Late Even If Delay Is Due to Reconciliation?
BenefitsLink Message BoardsLink to more items from this source
Jan. 28, 2021

"A few times in the past year a client has made the payments to TPA on time but TPA did not allocate them to the participants' accounts right away. It seems it's because the file sent by the payroll provider did not match the amount paid. When this happens the TPA holds the funds until they can reconcile, at which point they apply them. It seems like these shouldn't be late contributions. Any authority for this conclusion?"

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