How do I determine when participant contributions to pension plans are late?
The general rule is that contributions (other than union dues) withheld from an employees wages or paid to the employer by a participant must be sent to the plan on the earliest date these contributions can reasonably be separated from the employers general assets. This means that if you know how much should be sent to the plan three days after the pay date and it takes you another day to prepare the check, you must submit employee contributions four days after the pay date. In no event may these contributions be forwarded later than the 15th business day following the month of withholding. We expect that most employers can forward employee contributions well before this maximum time period ends.
