Screen plan accounts for participant amounts deposited late

Key facts

Human involvement
YellowClose supervision
How AI is used
From the accounts the lawyer marks, list each amount withheld or paid to the employer, the date it would have been paid in cash or was received, and the date it was deposited. Do not call a row a breach.
What the lawyer must review
29 C.F.R. § 2510.3-102 treats participant contributions and participant-loan repayments as plan assets from the earliest date they can reasonably be segregated from the employer's general assets. For a pension plan, that date is in no event later than the 15th business day of the following month. For a plan with fewer than 100 participants at the start of the plan year, deposit by the 7th business day is an optional safe harbour, not the only way to comply. A business day is any day other than a Saturday, a Sunday or a federal holiday. This screen only lines the accounts up against those dates. It does not decide a prohibited transaction, and it does not describe a correction. The employer's own contribution is not this regulation. Opinion 512: check a sample of rows against the accounts.
Written for / version
United States versionUSCth

Who does what

Who does what
RoleWhat they do
AssistanceConsider narrowly defined preparation support after confirming the tool’s capability and permitted scope.
LawyerSet the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output.

Checklist

  1. Trace every relied-on figure to its source, confirm dates and assumptions, and independently recalculate totals or derived amounts.
  2. Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
  3. Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
  4. Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.

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