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We have a client who has failed to withhold deferral payments on bonuses for several years. The affected participants will also be due a match contribution on the missed deferrals. This affected both HCEs and NHCEs and will be corrected under VCP. A question is coming up as to what happens with the prior ADP/ACP tests. This plan has never used the ADP/ACP safe harbor. They did fail testing a couple of times in the years affected and a few passes that were close to the limit (based on testing where bonuses were not counted for deferrals and match). Are we reading the EPCRS procedure (section 6.02(2)(d) pasted below) correctly to interpret it as requiring that the ADP/ACP tests must be rerun for each of the affected years (likely resulting in late ADP/ACP corrections for the prior years that will also need to be corrected under VCP)? We'd like an outside thought before we implement any corrections. Thanks. (d) The correction method should not violate another applicable specific requirement of § 401(a) or 403(b) (for example, § 401(a)(4), 411(d)(6), or 403(b)(12), as applicable), 408(k) for SEPs, or 408(p) for SIMPLE IRA Plans, or a parallel requirement in Part 2 of Subtitle B of Title I of ERISA (for plans that are subject to Part 2 of Subtitle B of Title I of ERISA). If an additional failure is nevertheless created as a result of the use of a correction method in this revenue procedure, then that failure also must be corrected in conjunction with the use of that correction method and in accordance with the requirements of this revenue procedure.