About the Course
Introduction
This CPE webinar will provide EBP auditors with a practical review of late contribution deposits and other common operational failures in 401(k) plans, along with the correction mechanisms available to plan sponsors. Our experienced panel will examine how to identify these failures during an audit, calculate and document findings, and evaluate the appropriate correction path under current guidance.
Description
Late remittance of employee deferrals and loan repayments remains one of the most frequently reported audit findings. Small plans with less than 100 participants must make retirement deposits within seven business days of a pay date. Large plans, those with 100 or more participants, must make the deposit as soon as the funds can reasonably be segregated from the employer's general assets. Ensuring these deposits are made on time is a critical step in a 401(k) plan audit.
Other operational failures commonly identified during these audits include incorrect determinations of plan compensation, missed or miscalculated matching contributions, eligibility and enrollment errors, and improper application of forfeitures. EBP auditors must not only identify, document, and correctly calculate contributions but also be able to assist with the implementation of procedures to reduce recurring compliance failures.
Listen as our panel of accomplished employee benefit plan specialists provides a practical framework for identifying, evaluating, and testing late contributions and other operational errors in 401(k) plan audits, and discusses evaluating correction alternatives under current DOL and IRS guidelines.
Presented By
Mr. Ciminera is a member of the firm’s Employee Benefit Plan niche in the accounting and auditing services department where he specializes in auditing employee benefit plans of for-profit, nonprofit, and governmental entities. He also specializes in Form 5500 preparation. When necessary, Mr. Ciminera helps clients navigate and prepare filings for corrections of plan errors or late filings through the DOL Voluntary Fiduciary Correction Program, IRS Voluntary Correction Program, and DOL Delinquent Filer Voluntary Compliance Program.
Mr. Piccirillo is a strategic Fintech and HCM sales professional with 15+ years of experience helping businesses simplify complex payroll, HR, and retirement solutions. He specializes in consultative sales and client-first relationships that deliver measurable results. Mr. Piccirillo has a deep expertise in financial technology and SaaS platforms; he has helped over 500 companies implement retirement plans and supported 6,000+ employees in securing their future.
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BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.
Date + Time
- event
Thursday, December 3, 2026
- schedule
1:00 PM ET/10:00 AM PT
I. Fiduciary and Compliance Framework for 401(k) Plans
II. Late Participant Contributions
III. Consequences of Delinquent Deposits
IV. Correction Options for Late Deposits
V. Common Operational Errors in 401(k) Plans
A. Eligibility and enrollment errors
B. Compensation definition errors
C. Incorrect employer matching and nonelective contributions
D. Vesting and forfeiture administration errors
E. Failure to timely amend the plan
F. Other operational errors
VI. Audit Considerations
The panel will review these and other key issues:
• Determining when a participant contribution deposit becomes "late" under DOL regulations
• Evaluating corrective options, including the Self-Correction Program (SCP) and Voluntary Correction Program
• Audit reporting responsibilities and required disclosures
• Correcting missed deferrals, eligibility errors, and compensation issues
Learning Objectives
After completing this course, you will be able to:
• Identify common late contribution and operational errors in 401(k) plans
• Determine available IRS and DOL correction methods for plan failures
• Ascertain reporting requirements associated with plan compliance issues.
• Decide which failures qualify for the SCP or VCP self-correction programs
- Field of Study: Accounting
- Level of Knowledge: Intermediate
- Advance Preparation: None
- Teaching Method: Seminar/Lecture
- Delivery Method: Group-Internet (via computer)
- Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
- Prerequisite:
Three years+ business or public accounting firm experience at mid-level within the organization. Specific knowledge of accounting principles and an understanding of Employee Benefit Plan Audits.
BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.
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Late Contributions and Operational Errors in 401(k) Plans: Correction Programs and Audit Considerations
Thursday, December 3, 2026
1:00 PM ET/10:00 AM PT
