Part 1: Eligible Compensation

Part 2: De Minimis Balances of Terminated Employees

Part 3: Maintaining Documentation

Part 4: Timely Remittance

Common Finding

Per the IRS and DOL, retirement plan withholdings should be remitted to the Third-Party Administrator (TPA) or Custodian/Trustee as soon as “administratively feasible.” Administratively feasible is considered to be approximately the same time it takes to remit payroll taxes. This timing varies from employer by employer; however, the typical timeline is somewhere between 0 – 5 business days from the payroll pay date.


Schedule the day you make remittances to be the same each pay period and set a calendar reminder for the day the remittance needs to be made. For example, Company X has a bi-weekly payroll and payday is every other Friday. The following Monday, the payroll clerk has a calendar reminder to remit retirement plan withholdings. Make sure that more than one employee is trained and able to make the retirement plan remittances. Just because your payroll employee is on vacation does not mean you get a pass on the administratively feasible time limit.

If you find that you did have late remittances, you should contact your TPA representative and consider going through the DOL’s Voluntary Fiduciary Correction Program. This involves making a corrective contribution to lost earnings to the participants. Late remittances are required to be disclosed on the annual financials (if large employer) and Form 5500. The amounts must be disclosed until the lost earnings to the participants are corrected.