Ongoing DB plan fails to limit distribution to restricted employee (HCE benefitting under plan) as per 1.401(a)(4)-5(b)(1) and fails to obtain secured repayment obligation per Rev. Rule. 92-76. Occurred during 2019 plan year. As to correcting this, it seems like the choices are either contribute so that assets equal/exceed 110% of current liabilities, and/or obtain a properly secured repayment arrangement. But these would not reach back to when the violation occurred -- they'd be done currently (of course, no harm in last 20 months so no foul?). Any thoughts? Also, probably needs to be VCP -- Thoughts are appreciated.
