We brought in a new plan in April 2016 and found out in March 2017 that the 2015 ADP refunds were not distributed.
In lieu of QNEC, I think the one-to-one correction method (refunding excess contributions too) is going to be the cheapest route for fixing. I cannot find the in the EPCRS language or in the EOB books that this is also a QNEC deposit. The EOB just says "corrected with a contribution".
This correcting contribution is a QNEC, right?
Thanks