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How Should 401(k) Plan Contributions Be Handled When There Is a Temporary Liquidity Crisis?
Butterfield Schechter LLP 
Apr. 10, 2023 "In the event of missed or delayed payrolls, no issues arise with employee deferral contributions (since no payroll means no deferrals are taken). However, when payrolls resume, an evaluation of the impact of missed payrolls on participant loan repayments is necessary to account for any catch-up payments or re-amortization of future payments that may be required. Furthermore, any employee deferral or loan payment remittances from prior payrolls that may not have yet been contributed to the plan trust should be deposited in the plan trust as soon as possible." |
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