What it is
Under 29 CFR 2510.3-102, participant deferrals and loan repayments become plan assets as of the earliest date they can reasonably be segregated from the employer’s general assets. For a plan with fewer than 100 participants at the start of the plan year, a deposit by the seventh business day is deemed timely. For pension plans, the outer limit is the fifteenth business day of the month after withholding.
This workbook traces each payroll from the register to the deposit, counts business days using a holiday list, tests against the deadline you set and against the outer limit, estimates lost earnings on late amounts and ties the year’s totals to Forms W-2 and the financial statements. Late amounts feed the Form 5500 reporting of delinquent contributions.
When to use it
- Testing the timeliness of participant contributions in a plan audit.
- Quantifying late deposits and lost earnings for a plan sponsor.
- Tying contributions to payroll, W-2 reporting and the financial statements.
What’s inside
- Plan tab: participant count, safe harbor, deadline used, lost earnings rate, outer limit and holiday calendar
- Sixty payroll rows with business days to deposit, due date, days late and outer limit date
- Status flags, lost earnings estimate and employer contribution comparison
- Summary: late counts and amounts, averages, W-2 and financial statement tie-outs
Standard cited
This template follows 29 CFR 2510.3-102 / AU-C 703. It is written in our own words, except for phrases the standard requires the document to contain, with [bracketed placeholders] for client details, amounts in USD and dates as MM/DD/YYYY. Check it against the current standard and your firm’s methodology before use.
Questions
What if the plan has 100 or more participants?
There is no safe harbor. The test uses the deposit lag the plan’s documented practice and payroll capability support, which you enter on the Plan tab, and the outer limit still applies. Late deposits are prohibited transactions and are reported on Form 5500.
How is lost earnings estimated?
Late amount times the annual rate you enter times days late over 365. It is an estimate for planning. The plan sponsor and its advisors compute the amount to correct under the applicable correction program.
Are employer contributions tested for timing?
They are not plan assets until contributed, so the sheet compares amounts only. Test the employer contribution deadline for deductibility and the plan document separately.
How are business days counted?
From the day after the date the amounts would otherwise have been payable to the participant in cash (the pay date for most payrolls) through the deposit date, skipping weekends and the holidays listed on the Plan tab.
Related templates
- Employee Benefit Plan Audit Planning Memo (ERISA)
- Employee Benefit Plan Participant Data Testing Workpaper
- Form 5500 Schedule H to Financial Statement Reconciliation
Last updated 11/05/2026. All free templates.