Time penalties

Tenancy Deposits

I did not protect a payment received from a tenant until some 9 months after receipt. It is protected now. Are there any penalties? If so, on what grounds can I argue against imposing them? I do have reasons for not protecting initially, the tenant had applied for the local Housing Aid Deposit protection guarantee scheme and wanted to move in immediately. I accepted a payment, agreeing to refund when the gaurantee scheme was in place. The guarantee was never received and it was forgotten about until the tenant asked me where it was. I immediately paid it into the DPS.