Field Assistance Bulletin 2026-01 made late deposits of employee deferrals and loan repayments a DOL enforcement priority, and the agency is mining Form 5500 filings to find them. Small plans must deposit within seven business days of withholding; larger plans must deposit as soon as amounts can reasonably be segregated, typically two to three business days, with the fifteenth business day an emergency outer limit rather than a deadline. Ferenczy recommends written deposit procedures and prompt engagement with the Voluntary Fiduciary Correction Program when deposits slip.