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Minimum Coverage Requirements. In the case of a section 401(k) plan, a corrective amendment may only be taken into account for purposes of satisfying § 1.410(b)-3(a)(2)(i) under this paragraph (g) for a given plan year to the extent that the corrective amendment grants qualified nonelective contributions within the meaning of § 1.401(k)-6 (QNECs) to nonhighly compensated nonexcludable employees who were not eligible employees within the meaning of § 1.401(k)-6 for the given plan year, and the amount of the QNECs granted to each nonhighly compensated nonexcludable employee equals the product of the nonhighly compensated nonexcludable employee's plan year compensation and the actual deferral percentage (within the meaning of section 401(k)(3)(B)) for the given plan year for the group of NHCEs who are eligible employees. [§ 1.401(a)(4)-11(g)(3)(vii)(A).] I believe the bolded portion of the citation provides the formula for calculating QNECs. We had the approval of legal counsel in a similar situation and had no fears about defending our position under audit. I am just narrating our experience and hope it is helpful and no pressure to agree with my position!

Seem like an accounting issue. Can't you simply transfer some of the rollover source to the 401(k) source and reassign an equal portion of the loan to be repaid to the rollover source?

You might find this outline helpful; it has been requested 100's of times over the years. Compensation Outline 2000.pdf