401(k) Monitor

Late deposits of 401(k) contributions, as filed

13,904

13,904 large US 401(k) plans, 25% of the 55,904 that answered the question, reported on their Form 5500 that money withheld from participants’ pay reached the plan later than the law allows. The amounts they report add up to $3,791,398,235 for form year 2024.

Schedule H part IV line 4a, read from DOL EFAST2 Form 5500 bulk data. Plan years ended May 12, 2017 to November 30, 2025. How this data is built

What a reported amount is, and what it is not

This is a checkbox and a dollar figure on a government form, filled in by the employer about its own plan. It is not a finding of wrongdoing, not the result of an audit, and not a penalty. Nothing on this page is an accusation.

Schedule H line 4a asks whether any money withheld from pay reached the plan later than the law allows. A yes here most often means the employer found the delay itself, put the money in along with the earnings it would have made, and reported the correction to the Department of Labor under its Voluntary Fiduciary Correction Program. The filing instructions also require the same amount to be reported again every year until the year after the correction is finished, so this figure is not necessarily money that was late during this plan year. It does not mean participants lost money.

The typical figure is small. Half of the plans that answered yes reported less than $33,100, and 2,088 of them reported less than $1,000.

How the reported amounts are distributed

Under $1,0002,088 plans
$1,000 to $9,9992,549 plans
$10,000 to $99,9994,945 plans
$100,000 to $999,9993,686 plans
$1 million or more636 plans

The median amount reported is $33,100. The middle half of the filings runs from $4,054 to $143,322, and the mean is $272,684, which sits above the third quartile because a few very large filings pull it there. 636 plans reported $1 million or more and account for $2,407,820,002 of the total, so 13,268 of the 13,904 plans on this page share the rest.

The amount a filing states is the aggregate for the year, and a bigger plan moves more payroll, so a larger figure mostly tracks how much pay runs through the plan. Quartiles are the medians of the lower and upper halves, so each one is an amount a filing states or the mean of two of them.

How often the answer is yes, by plan size

Plan size (participants)Plans that answeredAnswered yesShare
100–499 participants35,9198,35623.3%
500–999 participants9,0602,42926.8%
1,000–4,999 participants8,3882,40128.6%
5,000+ participants2,53771828.3%

The share runs from 23.3% to 28.6% across the four sizes, so a yes says little about how a plan compares with its peers. The 7-business-day safe harbor in the rule below covers only plans with fewer than 100 participants, and every plan in this dataset has 100 or more, so none of them can use it.

The 25 largest amounts on the line

Schedule H line 4a asks whether any money withheld from pay reached the plan later than the law allows. A yes here most often means the employer found the delay itself, put the money in along with the earnings it would have made, and reported the correction to the Department of Labor under its Voluntary Fiduciary Correction Program. The filing instructions also require the same amount to be reported again every year until the year after the correction is finished, so this figure is not necessarily money that was late during this plan year. It does not mean participants lost money.

These are the largest figures in the dataset, not the worst cases: the amount is a total for the year, so it rises with payroll and with how many pay periods the delay covered. A plan name is a link when that plan has a page of its own here.

Schedule H part IV line 4a, form year 2024. Amounts in USD as the filing states them; participants are the beginning-of-year count. A pooled row is one filing covering many unrelated employers, so its amount is not one employer’s payroll.
PlanSponsorParticipantsAmount reported ($)
Sysco Corporation Employees' 401(k) PlanSysco Corporation60,63788,442,248
Ceva 401(k) PlanCeva Logistics U.S. Holdings, Inc.13,64379,959,556
Global Medical Response, Inc. 401(k) PlanGlobal Medical Response, Inc.39,95474,121,513
Profit Participation Plan Of Moody's CorporationMoodys Corporation8,09268,623,989
Elevator Constructors Annuity And 401(k) Retirement PlanBd Of Trustees Of The Elev Constu Annuity And 401(k) Ret Plan40,03453,242,766
Global Infrastructure Savings PlanT.Y. Lin International Group, Ltd2,66252,429,737
Barrick Retirement PlanBarrick Gold Of North America, Inc.8,73450,492,081
Deferred Salary Plan Of The Electrical IndustryBoard Of Trustees Of The Deferred Salary Plan Of The Electrical Ind35,52039,161,609
Acrisure 401(k) Savings PlanAcrisure, LLC14,96635,496,602
The Communicare Employee's 401(k) PlanHealth Care Facilities Staffing, LLC14,61727,368,381
Geico 401(k) Savings PlanGeico Corporation46,81521,185,692
Radiology Partners, Inc. Partner PlanRadiology Partners, Inc.1,65520,456,395
Atlas Technical Consultants 401(k) PlanAtlas Technical Consultants, LLC5,40820,212,899
Radiology Partners, Inc. 401(k) Profit Sharing PlanRadiology Partners Inc.6,61120,122,250
JPMorgan Chase 401(k) Savings PlanJPMorgan Chase Bank, National Association299,27718,858,037
The Atlas Air, Inc. Retirement PlanAtlas Air, Inc.6,01618,305,079
Flex 401(k) PlanFlextronics International USA, Inc.11,27917,999,949
Park Nicollet Health Services 401(k) Retirement Savings PlanPark Nicollet Health Services11,33816,500,237
Southwest Key Programs, Inc. 401(k) Retirement PlanSouthwest Key Programs, Inc.11,23716,363,638
Olympus Corporation Of The Americas 401(k) Savings PlanOlympus Corporation Of The Americas6,53214,721,362
Trinet 401(k) PlanTrinet Hr Iii, Inc.Pooled filing, many unrelated employers249,20713,624,131
Ranger Energy Services 401(k) PlanRanger Energy Services, LLC2,19813,039,828
401(k) Plan For Employees Of Fanduel Group, Inc. And SubsidiariesFanduel Group, Inc.3,23112,470,605
Savewisetm Pooled Employer PlanNewport Group, Inc.Pooled filing, many unrelated employers26,23512,367,471
Elma Electronic Inc. Savings PlanElma Electronic Inc.45711,912,404

13,904 plans reported an amount, filed by 13,676 distinct sponsors, covering 23,232,929 participants. The whole list is in the download at the foot of this page, one row per plan, with this same caveat sentence on every row.

What the deadline is

The rule is 29 CFR 2510.3-102. Money a worker has withheld from their pay becomes plan assets on the earliest date it can reasonably be separated from the employer’s own assets, and the same rule sets an outer limit: no later than the 15th business day of the month after the month it was withheld. Line 4a asks whether anything missed that date. It does not ask by how long, and the Form 5500 does not carry the answer, so this site cannot tell you whether a figure covers one payroll run that went in two days late or a year of them.

Read 29 CFR 2510.3-102 ↗ · The DOL’s Voluntary Fiduciary Correction Program ↗

What this page does not tell you

Every figure here is self-reported. A plan that answered no is a plan that answered no, not a plan that was checked: 42,000 filings answered no, one left the line blank, and 1,919 of the 57,824 plans in this dataset filed no Schedule H at all, so the question was never put to them. Small plans filing under the 80-120 rule are most of that last group.

The figures cannot be added up across years. The Form 5500 instructions require the same amount to be reported again on line 4a every year until the year after the correction is finished, so one late transmittal can appear on several filings, and a total built from more than one form year would count it more than once. Everything on this page is a single form year for that reason.

A plan can also appear here without its employer being the reason. A payroll provider or a recordkeeper can be the cause of a delay, one sponsor often files several plans and the line is answered per plan, and a pooled filing covers a book of unrelated employers under one sponsor name. The filing names none of that, so neither does this page.

401(k) Monitor, “Late transmittals of employee 401(k) contributions reported on Form 5500 Schedule H line 4a”, 13,904 plans and $3,791,398,235, computed from DOL EFAST2 Form 5500 bulk data, form year 2024. A reported amount is self-reported and most often accompanies a correction the employer made itself.