💵
Late Deposit Information
Enter details for each late participant contribution
Plan Details
📊 Plan Size
Small Plans (<100): Have a 7-business-day safe harbor for deposits.

Large Plans (100+): No safe harbor. Must deposit "as soon as reasonably possible."
📆 Pay Period
Your payroll frequency affects when contributions should have been deposited. The "Loss Date" should be when funds could first be segregated from employer assets.
Entry Mode
Late Deposits

📋 Quick Reference

7%
Q1 2025 Rate
$1,000
SCC Threshold
180
Days for SCC

💡 Field Guidance

$
Principal Amount
Total late contribution amount (employee deferrals + loan repayments if any).
📅
Loss Date
When funds should have been deposited (segregated from employer assets).
✓
Recovery Date
When funds were actually deposited to the plan trust.
📊 Calculation Details
# Principal Loss Date Recovery Date Days Late Lost Earnings
📖
VFCP Deposit Rules
Key deadlines and safe harbor guidance
🏢 Small Plans (<100 participants)
7 Business Day Safe Harbor: Contributions deposited within 7 business days of the pay date are presumed timely.
🏛️ Large Plans (100+ participants)
No Safe Harbor: Must deposit "as soon as administratively feasible" – typically 1-3 business days for automated payroll.
⏰ Absolute Deadline - All Plans
15th Business Day: No later than the 15th business day of the month following the pay date.
✨ NEW: Self-Correction Component (SCC)
Effective March 17, 2025: Self-correct without filing a full application if:
  • Lost earnings ≤ $1,000
  • Correction within 180 days of loss date
🗺️
Find Your EBSA Office
Regional office for VFCP submission
💡 Submission Options:
  • Mail to regional office address
  • Email to office email address
  • Electronic submission (coming soon)
📈
IRC 6621 Underpayment Rates
Federal short-term rate + 3 percentage points
Q1 2025
7%
Current
Q4 2024
8%
Q3 2024
8%
Q2 2024
8%
Q1 2024
8%
Q4 2023
8%

Rates are published quarterly by the IRS. Lost earnings are compounded daily using these rates.

📅
Correction Timeline
Key dates and deadlines for your correction
📁
Required Documents
Gather these before proceeding
📋
VFCP Application Checklist
Appendix B - Complete all required items for your application
1 Eligibility & Contact Information
Pending
Reviewed VFCP eligibility requirements
Confirm the plan is eligible and the breach qualifies for VFCP correction.
💡 Earnings(k) Guidance
Late deposits of participant contributions are one of the most common VFCP-correctable breaches. Your plan is eligible if it's an ERISA-covered plan and not currently under DOL investigation.
Contact person information included
Name, address (street or email), and telephone number of person familiar with the application.
Plan sponsor/administrator information provided
EIN, Plan Number, and address of both plan sponsor and plan administrator.
2 Certifications & Documentation
Pending
Penalty of perjury certification signed
Signed and dated certification from plan fiduciary with knowledge of the transactions.
💡 Earnings(k) Guidance
The certification must be signed by someone with actual knowledge of the late deposits - typically the plan administrator or HR director responsible for payroll.
Relevant plan document portions enclosed
Include adoption agreement, trust agreement, or insurance contract with relevant sections identified.
Most recent Form 5500 filing date provided
Date that the most recent Form 5500 was filed by the plan.
3 Breach Narrative & Correction
Pending
Detailed narrative of the breach included
Describe what happened, when it occurred, and how it was discovered.
💡 Earnings(k) Guidance
Example: "Due to payroll processing delays, participant contributions from the [date] pay period totaling $[amount] were not deposited until [date], a delay of [X] days beyond when they could have been reasonably segregated."
Lost earnings calculations documented
Include DOL Online Calculator printout or manual calculation per VFCP Section 5(b).
💡 Earnings(k) Guidance
Your Earnings(k) calculation is ready! Click "Export Report" to generate documentation. We recommend also running your figures through the DOL Online Calculator for verification.
Proof of payment to plan enclosed
Documentation showing principal amount and lost earnings were paid to the plan.
4 Excise Tax Relief (PTE 2002-51)
Pending
Class Exemption notice arrangements made
Provide copy of PTE 2002-51 notice to all interested persons within 60 days of application submission.
💡 Earnings(k) Guidance
If seeking excise tax relief, you must notify participants. If excise tax would be ≤$100, you can skip the notice by providing a completed Form 5330 with proof of payment instead.
Procedures implemented to prevent recurrence
Document measures taken to ensure timely deposits going forward.
📝
Application Summary
Review before signing
✍️
Electronic Signature
Sign under penalty of perjury
⚠️ By signing below, you certify under penalty of perjury that the information provided in this VFCP application is true and correct to the best of your knowledge.
Your signature will appear here
Authorized Signature
✓ Application Signed
,
Signed on