Failure to timely apply forfeitures
Top 10 retirement plan internal control pitfalls #3
The IRS view of accounting for defined contribution plans is that the plan needs to allocate all of the money in these plans at year-end to participant accounts; there are very few, limited exceptions to this rule. The IRS is finding that plans may have hundreds of thousands of dollars in unallocated forfeitures that are rolled over from year to year.
The general rule on forfeitures is that you use them to pay expenses or to reduce employer contributions in the plan year in which the forfeiture occurred (or add to employer contributions). That can be impractical with a daily valued plan, so you use the forfeiture in the following year.
The correction is difficult. If forfeitures remain in a suspense account for too long, the plan needs reallocate the forfeiture to participants who would have been entitled to the contribution had the plan used them in a timely fashion.