These are not the numbers, but I am putting in an example with numbers that may make it easier to understand:

Assume:
Testing failure said to refund $5,000 in ADP and refund $1,000 in ACP
The $5000 refund was made, but the 1,000 was not made.
The ACP refund will be made by the end of the year.
However, running testing to see how much the refund will be shows:
ADP refund of $4,500 and ACP refund of $800
Can we refund only $300 in ACP since the ADP refund is now $500 less than originally calculated?

Huh? Why did it go from 5.00 to 4,500? You lost me there...

But no, there would be no basis for crediting ADP refunds as ACP refunds. You're only hope would be if it happened to be from a pooled account, since there is nothing in the distribution pointing to ACP (ok, maybe the paperwork..).

But it might help to know how all of a sudden the numbers changed...