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Pre-PPA (a/k/a GUST) documents frequently allowed forfeitures to be used as SHNE contributions. As noted, MOST PPA documents now restrict the use of forfeitures to fund SHNEc's. I would guess that those that don't have the SHNEc restriction constitute a mistake on the part of the IRS. Every PPA document I've seen, of course, has the QNEC requirement that they can only come from monies which are 100% vested when contributed to the plan. What is interesting is that the PPA documents I've seen draw a fine line distinction between the two prohibitions. QNEC's and QMAC's specifically state the requirement that they can only come from monies which are 100% vested when contributed to the plan. SHNEc's don't have that specific language. Instead, the restriction is specific to forfeitures. I acknowledge that forfeitures are precluded by document language from being used to fund SHCEc's. However, Tom's original question is whether the general prohibition on use of forfeitures to fund SHNEc's carries over to a similar prohibition on the use of a QRP's suspense account to fund the SHNEc's. And nothing in the language of the PPA document I've looked at makes that connection. Whatever happened to the general rule that "if it isn't prohibited, you can do it"? I lean strongly toward being able to use QRP suspense account funds. I note that the use of a SH 401(k) document as a QRP is somewhat internally contradictory. I suppose there are some documents that provide for some sort of dribble out of the QRP suspense account. But most I've seen are worried about having so much in the QRP suspense account that emptying it within 7 years is a real concern. As such, with participants bumping up against the 415 limits, why would you want a 401(k) provision at all?

... or during 2016.

I don't know why you think that would be an unexpected result. Seems like the natural result of a PC owned by 1 person being an adopting employer.